Method 23 -dioxins and furaos. In addition, I have reviewed historical trial bums perfonned by other qualified stackt:esUng firms (Midwest Researob, Inc), that were agency approved RCRA 

## trial 

## bUrDS, to assess their 3Uitlbility for use, along with BNSR's own testing -.wrlc, to address c:ompliaDce with 

### tbe HWC MACI' standards through the dala in lieu ofprovisions Providod 

### for in these regulations

. As staled previously, I know ofno bwlis to challenge the integrity ofthese actual data either. 

### S. 1

### have also been wotking on the**Com~ve** PerfOrmance Test Plans ("CPT") for the facility. The 

### foc::us ofthis worlc isto oomply with existing requltemcots, which necessitate CPTs 

## imd testing to be oompleted by Octobet 14, 2009. Though 1hat dc:adllne Is roughly eighteen months away, this is the nonnal lime frame to begin test plan preparation 

### so that the actual tests can be**~rformcd** on time to meet the regulatory deadlines. This schedule is also oonsistent with our praaice for the climts we serve and iB gene:rolly lnlo for the entire industry regulated under this rule. 6. I have reviewed the USEPA Region V's Request for Information 

### dated February 22, 2008. In essence, Veolia is requested to accomplish thc following actions by July IS, 2008:

• Prepare and submit three CPT Plans to the USEPA for q.ch ofthe incinetators at Sauget, including the required 

### Colllinuous MoqitOring System Performance Evaluation Test (CMSPB'I) Plans for each unit as well;

• Receive and respond to USEPA's comments on the CPT Plans (wblch ordinarily takes several months, but can tab up to a year or more to receive),
e Oblain final approval of IMCPTs ftom lhe US!!PA,

-3-

VES 0 04701• Prepare for the CPT, including mobilizing 

## needi:d teeds and spiking materials, preparing and 

### shipping all 

### teSt cqulpinMt, 

### making arrangements with analytical 

### laboratories and

. perfumting the 

### CMSPBT,

• Perform three CPTs, each requiring as mueb as a lUll woek to complete,

• ObWn the test resulta from 'die laboratory,**~aluate** these results and prepare eil.d submit the test report aod Nodficalion ofComplUmce to**~** USEPA.



### . . 7. Vcolia bas asked mo if tho requested testing, by 

### tbe July 15,2008 deadline, is feasible. In my opinion, the USEPA's request, in the gi'ml time frame, is neither feuible nOt' approprill!e S!ven tbe amount oftime needed to not only complete approvable plans, 

### but also to 

### conduct testing and submit tho required 

### reports. For a coromeroial facility ofthis complexity, USEPA's



# . . expected schedule is 1mprcccdented In my experience. 

### My reasoning for this Sllrtement is as follows: 8. The CPT Plans are complex and prior to thorn being conducted, require several 

### months to develop in sufficient detail In order for them to be approvable 

## by a regulatory agency.


### . . 

### The first step in preparing the CPT involves collecting sufficient facility related**inf~on** to :fulfi'l the information rcquitemen1s stipulated in the regulation (i.e., 40 CPR§ 6:1 .1207). In addition, curreot information on wa.!le streams JIWI8ged at each oflbc uoits will need to be COQ\Pilcd and swnmarlzed so that wbat 

### each unit treats is well characterized 

## ai1d the 

### feeds tlul.t will be used during the CPT will be representative. Sinoc these units treat many waste streams that differ both chemically and physically, this compilatiori generally takes acveral 

### weeks by itselfto complete. Then, from 

### this compilation, detailed p iWJS for testing need to be developed 

### J O

esta b

lish the desired feed and ope111ting conditions during the CPT that will then enable VeoUa
to establish tbe required waste feed and ope:ating parameter limlta (OPLs) required 

### to show

- 4-

V E S 004702ongoing compliance with the HWC MA,CT standards. This entails identifying the desired feeds, calculating their feed rates, detennining likely emission rates and assisting the facility I n selecting the 

### &8il'Od operating conditions so that the regulatory requirements for establishing each OPL can be established. Due to the complexity ofsetting each OPL, it will likely be necessary to condiiCI testing at more than one feed or operating oondition, all ofwbiob needs to be worked out in sufficient detail so that 

### each 

### l!lrlt can be opeaattd at 

### these desired conditions for

. sufficieot time to OODduct the emissions testing. Ooce 

### deta11s**~f**the 

### test design liave been finalized, dala qualityobjectives arees••blisbed and the sampling and analysis approaches and 

### methods must be finalized. 

### These details are incorporated into 

### e, specific Quality Assurance Project Plan ("QAPP"). This pO)'lion oftho CPT Plan has**e~tlellslve** de(ail deacribing tb8 sampling and analysis methods and related quality uswanee/quality oontrol ("QA/QC")


### measures thai w!U be followed by the facility, the stack t.esting finn and the analytical laboratories involved with tho CPT

. Once draft plans haw 

### been written, internal reviews are required with**~ility** operations staiTand planned subcontJaetors (e.g., specialty analytieal la bs) to review and 

### finali2t plan details to assure 

### thC tests can be perfonned as writte'n and the results will meet da1a quality objectives for tho program. · 9. TM CPTs for incinerators lfl andN3 will be similar. But the Plan forfl4 will be different 

### beeau!c Units 2 and 3 are 

### different technolOgies (Fixed Hearth ) from Unit 4 (Rotary Kiln), employ IIOIIICwhat dift'ema 

### air pollution control systems, feed**diff~t** wastes and operate undtz di.ffmnt c:onditioos. These differenees nec=itate separa!o and distinct test designs that will require specific feed rates, spiking rates, operating conditions and test schedules for each of the unit types. In addition, stack sampling ports and access to these ports differ, thus requiring

-5-

VES 004703separate and dis1in« scheduling and sequencing 

## oftestiQS activities

. Thus, scpa.ra1e CPT Plans need to be developed. 

### lo. omo ilie 

### Pliiii8 are submrtted; 

## ihCY must go tlii'Ough agency 

### review and 

### approval procedure.s. Typic:ally, agency review and approval for one affected sourc:e can easily take a. year
o

r more. For that reason, Veolla asked ENSR to begin the CPT process now ln order to meet the October2009 dCadfine. The applicabl e MACTregulatioos (40 C.P.R.§ 63.1207 etseq) provide timeftames for submitting such Plans and performing the needed testing. The regulations

. stipulate that CPT Plans must be submitted at least one year prior to conducting them tp allow

. for agency review and approval The regulations further !tlpulate a**~** frame (40 CPR § 63 .1207(c) (I(A)) of9months for the agency to notify facilities oftbeir intent to approve or disapprove the'CPT Plao. lt bas been my expcrieoce that CPT Plan reviews by regulatory agencies follow traditional 

## proceawes starting with an administrative completeness review,**foUo~** by a tccbnica! 

### review. Bo

. th ofthese reviews are typically lt e:ative processes that are managed through agency issued Notice of**~flclency** letters that require response and additional infollllation to be submiUcd. Normally, no matter how complete a facility feels their CPT Plan is

on submittal, the AgentJy provides input, typic:ally requiring several Plan rcvisiC?JlS before approval 

### is given to conduct the actual tasting. HlstoricaUy, agencies have often 

### spent several years reviewing trial bums under RCRA due to their complexity and the need for a thorough and complete Administrative Record to be on file supporting agency deoislonmaldng. Like the · R

CRA program, it has been my expetiooce under the HWC MACT CPT Plan review process that a&eneies do not expedite their review and approval procedures for the very same reason. In · fact, in 

### my experience it is essential for complcic and thorough reviews oflhe Plan(s) to**~ur** fa: both the agency's sake and to avoid 

### puq Veolia at risk of an unldenliticd problem not

-6-

VES 004704being discovered lllltillt ia too late, putting the entire CPT and the facility's ability to romply with an appropriate set oflimits injeopardy. 

### I

. 

### once ageocy 

### approva1"ts gtitite(l, pet!OfliiiJlg 

### tne actual 

### CP I ieqwm extellitve pre• planning, scheduling and logistics**actlvltie~~** to OCCUr before they can be oonducted to assure pii)Jler execution, typically taking several montits forjust one unit 

### Due to the general uncertainty in

### the timing llflhese approvals, fe.cilitios 

### and their stack

# testing wn1racton do not begin this process until approval Is given; Also, given the very nature ofthese types of 

### Programs, only 

### certiun teSting and analytical firms ,are truly qualified to oonduct them. Sinoe many facilities subjecl.to the HWC MACT regulqtioos are currently in various st&ges ofplanning and performing these programs, availability oftrained SI&Ck testing 

### crews, testing equipment and laboratory capacity must be p!arulcd several montbJ in advmcc just to secure scbeduling rommitments

. Also, from a pore logistics 

# pcrs!*live, many prepntory activities must take place 

### well in advance oftho actual fie ld pros!1IDl to e.ssurc file CPT i s pcrfomed 83 intended

. For example, testing equlproent must be properly cleaned, packaged for shlpment and shipped to tho facility. Glassware cleaning fur stack testing can take 

### up to two weeks to oomplete before it
e&n 

### even be packaged 

### for shipment 

### to the facility 

### for usc in the 

### test. In additiOD, test methods like EPA M 23 for Dioxins and

. F\lrans require specific sample train test media 

### to be prepared with pnHpil:ed compounds to address progre.m QA/QC requirements. La$1, but no t least, facilities must accumulate the uccessary feed and spildng materials and oond uct oomprehens!ve p-eparations of !heir uoil3 for the test program. such as instrument calibrations titst**~** required

as part ofaddressing the CMSPBTrequirements as stipulated ln40 CPR §

.63.8{o )(4) and 1207(bXI ). In order to assure adequate availa b

ility oftesting staff, equipment and laboratory capacity 

### to process sunplcs 

### within 

### their sample holding times and make sure that each CPT is

- 7-

VES 004705

### conducted so lhatit"meets 100% ofthe 

### performance 

# and quality :requirements, ouly 

### one unit 

### at a time is testod. AUemptina 10 Perform simultaneous test 

### programs on multiple units and maintain 

### quint)' periol'lJl8D()e, 

### Wlffi IDS1iffica enl .read tame 

### Is 

### a recape for tllilUte) which 

### IS an unacceptable ou!I:Ome for all involved. 12. Even OJ) an expedited basis 

### and doing 

### one inci.neralor at 

### a time, it wo'!]d 

### reasonably



### . . lllke two months to 

### prepare the CPT Plan. Then, once approval oftbe

### Ag~ is obtained, it would 

### 181cc Q1lll 

### molllh or more to pzepare 

### for and 

### schednlcd the 

### CPT,

### ~week to 

### cooduct tbe testing and another several weeks to get the results ofthe 

## tests summarized (the 

### regulations allow submittal ofresults up to 90 days after completion ofthe CPT)

. 

### FURTHER AFFIANl' SA YBTH NOT.

SWORN AND SUBSCR1BED Before 

### me this 

# J!taay of

### Marcla, 2008.

-8-

V E S 00 4 706

## VES 004707

. pdfKellmeyer , Joseph From: Sent: To: Cc: Subject: Attachments:

Dear Ms. Newton, Grei g.Siedor @veo liae s.com Tu esday , March 11, 2008 11:25 AM Newton
.C heryl @epa

.gov

### Oennis.W~rch**ol@veollaes.com;** Dou g .Ha rris @veoliaes. co m; Kellmeye r, Joseph

. Attached letter Ne wton lttr 031108

. DOC

Th ls letter relates to the i ssues we will be discussing wit h yo u and your colleagues at our meeting on March 13,2008 at RegionS's offices In Chicago

. 1 am also sending It to you vla fax (312·353·1661) and UPS. Tha nk you. we loOk forward to a p roductive meeting on th e 13th

. (See attached fi l e: Newton lttr 031108

. DOC )

Gre ig R

. S

l edor Ch i ef L egal Officer Veolla ES Tech nical Solutions, LL.C. ( form erly Onyx E nvi ronmental Se rvices, L.L. C .) 700 East Butterfie l d Road , Suite 201 Lombard IL 60148 630.218 · 1635 (fax) 630-684-7013 greig

. s i edor@veoliaes.oom ww_w,veol!aes.com

VE S 0 047 07V\A UPS , email and FAX to 312-3 53- 1661 March 11 , 2008 Cheryl L. NewtOn A- 181 A

c ting Director of Air 

### and Radiation Division United StateS Environmental Agency, Region V 77 West Jackson Blvd

. C l1icago, lL 60604

-3590 

### Re: PTeliminary 

### Draft of Title 

### V Permit 

### Dear Ms. N ewton: 

### l am in rw:ipt of the letter from you 

### received on 

### March 3, 2008 , which also enclo sed 

### a preliJninary draft of a Till e V operating permit !or Veolia's Sauget, lllinois' facility 

## witli. a rtCJ.Uest for inlorrnal comments by April 

### IS , 2008

. We appreciate your letter

. 

### VeoUa will provide any 

### informal comments it may hav e to the draft Tille V operating permitund er s eparate 

### cover by 

### April 15, 200 8. The reason I am writing to you today is to correct 

### cenain inaccurate assertions contained within your undated cover letter. I n that letter, you state: [djuring our review of the data used to calculate the OPLs in your application , we have identified numerous flaws that compel 

### us to conclude that reliance on these Ok'Ls will not ensure Veolia's compliance with the applicable requirements in the HWC MACT

. As you 

### are aware, the Illinois Environmental Protection Agency similarly identified problems with the data when it was drafting a Tille V operating permit for Veolia under its C l ean Air Act Permit Prouam

. Furthermore, beca u se of the Jack o f usable data, EPA is unable to calculate OPLs to incorporate into the preliminary draft permit

. ( Emphasis added. )

VES 004708I, along with outside counsel Joseph KeUmeyer from Thompson Coburn, was present when Veolia discussed the collected data wit h fllinois Environmental Protecti on Agency ("!EPA" ) at a meeting In Springfield IL on April21, 2006. Contrary to your assertion, we were never advised by IEPA of any "flaws" in the data

. Si milarly, 

### !EPA never advised that they had an issue with regard to the accuracy of the data collected. Rather, the only purporred issue was the lack of recent data on Incinerator 3

. Historically, Veolia had submitted test plans and schedules before condu ct ing uial burns and similar restS on the Veolia incinerators and TEPA and USEPA were al

so present for many of the testS. In addition , pursuant to Veolia's RC 

### RA perm. its and the Code of Federal Regulations, data from lncinerator 2 had been used by Veolia since the early J990s in lieu of testing Incinerator 3 (and vice versa)

. Notwithstanding this long-standing practice, in response to !EPA's request and in an effort to cooperate with !EPA, Veolia (on a 

### very short sch edule requested by !EPA) subsequently and at great cost teSted and developed actual data from Incinerator 3 during the May-June 2006 time frame

. Additionally, there were 

### some**d~<;CUssions** during our meeting with TEPA concerning the method of extnapola tion from existing data. However, as I am sure you know, extrapolation I ssues are functionally and fundamen tall y differen t than "flaws" and " problems with the data.N At the time of the discussions with lEPA as well as today, Veolia continues to believe in th e integrity and the accuracy of the data it has provided

. I do not wish to make too much of the inaccurate statement contained in your l etter, and we are confident that this was inadv ertent; however, I do believe it is important to set thi s part of the record straight. I realize USEPA has only relatively recently taken on the role as the lead agency in volved in evaluating Veolia's Title V applicati on and , unlike myseU , USEPA did not h ave the benefit of being present during Veolia's meeting with TEPA to d iscuss the data. Veolia is**edi~ted** to the belief that IEPA , US E PA and the public must have an accurate record to rely upon . Please feel free to contact 

### me with any questions you may have relating to this or an y oth er matter
. Very truly yours,
Greig Siedor Chief Legal Officer

CC: Ms

. Julie Armitage, IE.PA· BOA Mr. Mi chael Reid, IEPA·BOA MI. Joseph Kellmeyer, Thompson

-Coburn Mr

. Doug Harr is, Veolia

VES 004 709

## VES 004 7 10

. pdfFrom : Qous

.Harfis@veoliaes

.com !mailto:Doug.Harri s @veoll aes . com] Sent : Frid;y, March 21, 2008 2:24PM To: Ncwtoo.Chervl@epa.gov Cc: Blakley.Pamela@epa.gov; Damico.Genevieve@epa

. gov; Woolums.Jane@epa.gov; Haii.Charles@epa

.gov; Ramatv.Todd@epa

. gov; Blough James@ep a.gov: G rejg

. S !edor@veollaes.co m; Kellmeye r , Joseph; CDool!ttle@ensr .aeco m.com: Davi d .Kiarich@veoliaes.com; Oennjs

. Warchol@veollaes

. com Subject: CPT Schedule for Incinerators 2,3 and 4

As 

### we discussed during our March 13 meeting. we are forwarding tile testing schedule for Incinerators 2 , 3 a nd 4. You'll find attachmentl being the I ntegrated schedule for all three i ncinerators. Attachments 2, 3 and 4 are the Indi vidual schedu l es tor Incinerators 2 , 4 and 3, respectively

. Please do not hesitate to can w ith any questiOns or comments
. (See attached file: CPT Integrated Schedule for 2,3,4_March, 2008.doc)(5ee attached file: CPT Schedule for #2_Marth, 2008.do c )(See attached file: CPT Schedule tor "4_March, 2008.doc)(See attached flle: CPT Schedule for U3_Mar ch

, 2008.doc)

/

V E S 0047 1 0

### Iut

pu r atio n Develop CPT Plan for Unit 112. Submit Unit il2 CPT P lan oo Agency. Agency apP<Oves Unitlt2 CPT Plan.' Begin pro<:= oo have the Unit12 CPT Plan made available to the public for at least 60 clays and issue public notice to fll<.ilil)l/public mailing llot per 40 CFR §63.1207(e)(2)

. Unit H2 CPT planning, scheduling, an d logistiCl activities commenced by ENSR and Vcolia. Submit CPT Plan for Unit #4

. Agency approves Unh #4 CPT Plan.' Begin process to have tbe Unit #4 CPT Plan made availabl e to the public for at leasl 60 days and i55ue JlUblic n()!ice to filcilil)l /public mailing list per 40 CFR §63.1207(e)(2). Unit 114 CPT planning, sch<dulinll. and logistics oaiviries commenced by ENSR and Veolla

. Unit il2 CPT P lan available to public for atleaS160 days and issue public notice to filcilil)l/publit mailing list per40 CFR §63.1207{eX2)

. Co mmence Unit #2 testing. • Com plete Uni t #2 testing. Submi t CPT Plan for Unit #3. Unit #4 CPT Plan avai l able to public for ;It least 60 days and issu e pub lic notice to focilityf public mailing lis t per 40 CFR §63.1207{eX2) .' Agency approves Unit #3 CPT Plan

. • Begjn process to have tbe Unit NJ CPT Plan made available to the public for at leaS! 60 days and issue public notice to fil<ilil)lipublic ma.iling list per40 CFR §63

. 1207(eX2). Unit N3 CPT planning, scheduling, and logirtlcs o<rivirtes commenced by ENSR and Veolia

. 60Days

IS Days

14 Days

64 Days

IS Days

63 Days

IS Days Anticipated D!te 1 ' o Be Comnlcted 1 May 15 ,2008 May 15.2008 May 30,200& M

ay )0, 2008

July I. 2008 July IS, 2008 July 15 , 2008

AugU1t I, 2008 •
August I, 2008 A

ugust 

### Is. 2008 September IS , 2008 September I S, 200&
September 30, 2008 Seplernber 30, 2008

VES 004711AnH(Jnated Task puratlon Date T o Be Camnleted 1

Unit112 CPT Report submitted to Aieucy .' 60 Days Oct ober 14,2008
Notificalion of Compliance (NOC) for Unit #2 90 Days November 13, 2008

submitted to Agency. ' Finding of ComplianCe ftom AgenCY fur U nit # 2. 1 JODays November IJ , 200 8**Comm~ nce**  U nit 114 testing. t De<;ember I , 200 8
U

nit i 3 CPT P lan a vailable to publ i c for at least 60 63 Days December I , 2008 days and**i~** public notice to facility/public m!liling liSt per 40 CFR §63. 120 7(c)(2). 10
Complete Un it 114 teSting. IS Days December IS, 200 8
Unit #4 CPT Report submitted to Agency

. " 60 Days Febroal)' 13, 2009
NOC for U nit # 4 submitted to Agency

. 11 90 Days M arch \ 3, 2009 Finding ofCompliance from Agency for Unit H4

. " 31 Days March 1 6, 2009
Commence U n

it §3 testing

. " April I, 2009 Complete U nit #'3 t eSting

. IS Da ys April IS , 2009
U

nit li3 CPT Report submitted to Agency

. ,. 61 Days June I S, 2009
NOC for l!nit #3 submitted to Ajency

. " 90Days July 14 , 2009 Finding ofComplisnce from Agenc y for Unit #3

. JODays August\4, 2009

1 Opportunities may exist in this schedule th o t could result in tasks being completed earlier than the anticipated date of completion. Conversely, throughout this CPT schedule dUll Vcolia is proposing, onlicipa ted completion dates are based on previous actions being compleled on the given date. If these previ ous actions aro not fini shed by the listed duo date, it may be nece ss..-y to extend subsequent completi on dates.
1 Ifapproval ofthe Unit 

## *2 CPT Plan exceeds I) days, the May 30,2008 completion date , and s ubsequent task ccmpletion dates, will be nwioed to**~nee\** this e<tension ofthe schedule.

' lfappro''al oftbe Unit li4 CPT Plan exe«ds 14 days. the July U, 2008 completion date, ond subsequent tzsk completion dates, may be

### ~vised to reflectIbis extension ofthe schodulc. Due to the early submittal ofthis plan, a delay in A&ency opproval may not affoct the schedule

. • If a delay in the commencement ofthe Unit 112 CPT occ\lfS that is beyond the control ofVcol i ll, the Augusol, 2008 date for starting this toiling, and subsequent taSk completion dates, will be revised to reflect this extension ofthe schedule.

VES 0047 1 2'This process will be repeated ifchanges In the a pproved CPT Plan for Un it 114""' made. lfthi

. s p

rocess is repoatod, subsequent task completion dates may be revised to reflect an extCilSion ofthe sclledule.

' Ifapproval ofthe Unit r3 CPT Pl•n exceeds IS days, the Seplember 30,200$ completion dale, and

wbsequent task compl etion dates, may be revised t o reflect dtis extension ofthe schedule. Due t o the early subminal ofth is plan, a delay i n Agency approval may notaffecc the schedule.
1 If Unit U2 test results arc n01 oblained in a timely manner Ot are flawed in some way thai would delay the

submittal ofthe CPT rcpon and the NOC, the Oetober 14,2008 and the Nov ember 13, 2008 com p

let

ion dates, and subseq uent tnsk completion d ateS, will be revised to rellect this extetuioo oftbe schedule. ' Ifthe Finding of Com pliance for Unit #2 exceeds 30 days, the November 13. 2008 completion date. and subsequent task com pletion dates, will be revised to reflect th is extension of the schedu l e. 'Ira delay in thecommencemont ofthe Unitl/4 CPT OCCW'S that is beyond the con lro l ofVool ia (e.g, the Fi nding ofCcrnpl i 3nce for Unit #2 has not been recei ved), the December l, 200 8 date for Slarting thi s tuting, and subsequent task completion dates, Will be revised to reflect this extension ofthe sebedule

. "This process will be repeated ifchanges in the appro• • ed CPT Plan for Un i t #3 are rnade. If thi s p rocess is repoated. su bsequent task completion dates may be revised to reflecc an extension of the schedu le.
11 If Unit #4 test resu lts are not ob tained in a timely manner or are flawed in somo way !bat would delay the submittal ofthe CPTrepO<t and the NOC. !be February 13.2009 and the March 13,2009 completi on dates, and subsequent task completion dates, will be revised to reflect this extension ofthe schedule.

" Ifthe l'indin& ofCompliance for U n

it # 4 exceeds 3 1days, the March 16,2009 compl etion dlte, and subsequ ent task completion dales, will be revised to rellect this extension ofthe schedule

. " I

fa delay in the co mmencement ofthe Unit ill CPT occurs that is beyond the contro l of Yeolla (e.g.. the Finding ofCompliance for Unit #4 has not b een received), the April I, 2009 date for startin g this testi n¥. and subsequent task completion dales, will be revised to reflect th is extension ofthe schedule.

' 'If Unit f3 lest results are not obtained in a timely manntf or are fl o wed ln some way that wou l d del ay the subm i t tal oft he CPT report and the NOC, tho June IS, 2009 an d July 14,2009 completion dates, and subsequent task completion date. will be revised to reflect this extension ofth e schedu l e.

V ES 0047 13VES 004714Comprebensjve Per f ormance Testing 

### <CPT)

### Schedu**~** for Vegl iR In cinerator #:Z,
Antisipatcsl Date 

### I •, Be Co mnlsted 1 

### Ia!l> J>un tlo• Develop CPT Plan for U nit 112. 60Days May IS, 2008 May IS,2008 S

ubmit Unit 112 CPT Plan to Agency

. Agency approves U nit 112 CPT P lan. 2 IS Days May30,200S Seg\n 

### process to bave the Unit Ill CPT Plan m* May30, 2008 available to the public fo r at least 60 da ys and Issue public notice to facililylpublic mailing li$1 per 40 CFR §63.1207(eX2)

. Unit H2 CPT planning, scheduling, 81.\d logistic> activities cot nmeneed by ENSR and Voolia. Uni t H 2 CPT P l an avai labl e to p u

blic fur nt least 60 64 Days AuguSI 1, 2008 days and issue public n otice t o C-.cllitylpublic mailing list per 40 CFR §63

. t 207(eX2). Cm•mence Unit fi2 testing.' AU&\LSt I. 2008 Complete Unit 112 testing

. 15 Days Auaust IS, 200&

U

nit i12 CPT RepOrt submined to Agency.' 600 ays October 14, 2008
Notif!C8liun ofCom pl iance (NOC) for Unh H2 90Days Novembe< 13. 2008

submitted to Ag ency.' Finding ofCompliance from Agen<:y for Unit 

## •z. ' 300ays November 13, 2008

1 Oppor1Uilit ies may exist in this schedule that could I'OSUlt in tasks being completed earlier than the anticipated date of completion. C onversely, throughoutthls CPT schedule that Vcolia is proposing, anticipated completion dates are based on previ ous actions being completed on the given dat e. 1 f these previous acti ons

### ar~ not finished by the list ed due date, i t may be necessary to extend sub$cquent completion dales

. ' If approval ofthe Unit H2 CPT Plan exceeds 15 days, the May 30,2008 completion da te. and subseq u

ent 1ASI< completion da tes. wiU be revised to reflect this extensi on nfthe scb<dule

. 'I fa dela y in the commencement ofthe Unit lil CPT occurs !bat is beyond the eonuol ofVeoliA, the Au gust I, 2008 da!e for startin& this testing. and su\loequenttask completion dates, will be revised to reflect this extensioo ofthe sclteclule.

VES 0 047 1 5' If Unit #2test results

## •~ not oboained in a timely manner or are flawed in some way that would delay the su

bm i nal oflhe CPT report and the NOC, the October 14 ,2008 and the November 13,2008 complelion dates, and subsequent task compl eCiOt> dales,

### will~ revised to reflect this extenS ion oflhe schedule

.

' I

f the Finding ofCo"'4'lionce for Uni t 112 exceeds 30 days, the November 13,2008 completion d at

e, and

### ub~quenttask completion dates, will be ro vised to reflect this extension oflhe schedule

.

VES 0047 16Comprehensive Performa nce T esti ng CCPTI Schedule f or Veolla I n cin e rator #4

AntiCh!l tt."(} 

### IW Duretj on Datt ,To Be Cumpleted '
Submi t CPT Plan for Unit 114. Ju l y I , 2 008 Agency approves U ni1114 CPT Plan.' 14 Days July 1 

## s, 2008 Begin prooe$S to bave the Unit 114 CPT Plan made July I S. 2008 available to the public for at least 60 days and issue publi<: notiee to filcility/public mailing list per 40 CFR §63.1207( e)(l )

. Unit #4 CPT phuming. scheduling. and logistic:s activities commenced by ENSR and Veolia. Unit #4 CPT Plan available to public for at least 60 63 Days September 1 S, 2008 days and issue publi c notice to f acility/public mai l ing list per 40 CFR §63.1207(eX2) .' Conunenee Unit #4t<sting

. 9 [)«ember I, 2008 Complete Unit 114 testing. 1 5 Days December 1 S. 2008
Unit 114 CPT Report submitted to Agency. 11 60Days Februory 13,2009
NOC for Unit 114 submitted to Agency

. 11 90 Days M arch 13,2009 finding ofCompliance from Agenc)' for Unit 114

. 12 31 Days March 16, 2009

1 Opponunities may exist in this schedule that coul d result in taSks being completed earlier than the anticipated date ofcompletion

. Conven;e ly , throughout this CPT schedule that Veolia is p roposing, anticipated completion dates are based on provioll!l octions b eing completed on the given date. lftheoo previous actions are not finished by the listed due date, il may be necessary to extend s ubsequent completion dateS.

' If approval of the Unit 114 CPT P lan exceeds 1 4 days, the July 1S, 2008 compl etion dat e, and sub<lequrot task completion dat os, may be revised to reflect this extension ofthe ..,hedulo. Duo to the early submittal ofthis plan, a delay in Aaency approval may not affect the schedule. 'This process .. ill be repeated if cbanges in the approved CPT Plan for Unit 114 are made

. If t his process Is repeated, subsequent task completion d.\tes may be revised to reflect an extensioo ofthe scl>edul e .

' \ fa dela y in the commencem<nt ofthe Unit 14 CPT 

### oeeun that is beyond tbe control of Veolla (e .g., the Finding ofCompliance for U n

it 1 2 has no< been recei"ed), the D<eomber I , 2008 date for $!liYiing this testing, and subsequent task completion dates , will be r<:vised to reflect this e x

tension o flh e schedule.

VES 00471711 IfUnit #<I test results are not obtained In athnel y manner or are flawed in $om< way lhat would dela y 

## me submiaal ofthe CPT report and the NOC, Ihe FebruBJ)I 13 , 2009 and the Marcll 13, 2009 completion dates, and subsequent task completion dates, will be revised to reflect th is extension ofthe schedul e.

12 If the Finding of Compliance for U nit/14 exceeds 31 days, the March 16,2009 completion dute, and subsequent task completion dates, will be revised t o refle<:t this extension ofthe s cl>tdule

.

VES 004718

### Compreb e nsiye Perf or manec Test ing < CPTl Sch edule for Veolia**In ci** **tor #~** 

Ant!dnated 

## :rm Dv raUo • Date Tg B q Co mnl eted 1

Subtl'lit CPT Plan for Unit #3

. Septt 'mber I S, 2008 Ageoey approves Unit #3 CPT Plan. ' IS Days September 30, 200 8 Begill process 10 have lhe Unit #3 CPT Plan made Seplcmber 30, 2008 available to lhe pub lic for at least 60 days and Issue public notJce to r.citityipubtic mailing lbt per 40 C FR §63.1207(e)(2). Unit li3 CPT planni!l$

. scheduling, and logi>tiCS activi ties commenced by ENSR and V eolia. Unit #3 CPT Plan available to public for at \ east60 63 Days Ow:mbor I , 2008 days and issue public noti ce t o facility /p

ublic mailing list p er 4 0 CFR §63

. t2 ()7(e)(2)

. 10
Co mmence Unit #3 testi ng. " Ap ri l I, 2009

Complete Unit #3 testing. IS Days April IS, 2009

Unit #3 CPT Report submitted t o Agency . " 61 Pays June 13,2009
NOC for Unit 113 submitted 10 Agency. 14 90 Oa)'S July 14,2009 Finding ofComp liance ftom Agency for Unit N3

. 300ays Au&ustl4, 2009

1 Opportunities may exist in th is sc hedule lh a t cou ld result in taSKs bei ng compl eted earlier than the anricipated dat e ofcompltiion. C onve rsel y, t hrOIIgho u

t this CPT schedule that Veotia is pr oposing. anticipated completion dates are based on previ ous actions being completed on th o gi v

en date. If t h

ese p

r evious actions are notlinlshed by the listed due dat o, it may be necesS8ry t o extend subsequen t completion dates

. ' l fapproval of the Unit #3 CPT P lan exceeds I Sdays, t he SeptemberJO , 2008 c om plet ion date, an d subsequent task complet io

n dat es, may be revised to re flect this extension of the schedu l e. Due to the early submittal o f this plan, a d el a y in A&e n ey a wrovat may not affect the schedu le.

1 0 This pro=s wUI be repeated if chanSOS in the approved CPT Plan fu< Unit N3 arc made. l rthis process is

### rc~ subsequent task completion dates may be revi;ed 10 rcllect an extension ofthe schedule

.
u If a delay in the commencement ofthe Unit M3 CPT occutS that is beyond the control ofVeolia (e.g , the Fiedin' ofCompliance for Unit 114 \lloS not been recei ved), the April I, 2009 date for statting this tesllng, and subsequent task completion dates. wiU be revised to Nflect thls ex tension oflhc schedule.

V E S 0 04719" IfUnit #3 tes1 results are not obtained in • ti mely manner or are flawed i n some way that would delay the submittal of !he CPT report and the NOC

. the June 15, 2009 md July 14, 2009 completion dates, and su

bsequenttaSk compiMion date, will be revised to r eflect this extens i on of the schedule

.

VES004720

## VES 004721

. pdfUNITED STATES BNV%RONXZlftAlo PRO'l'&CTION Ac;DIC:Y REGION 5
IN TIUC MATTD. OFI 

### Veolia ES Technical Solutions, LLC I 

### Mobile Avenue Sauget, Illinois 62201 .t.'rTUI'l'ION • 

### Dou glas Harris, General Manager Request to

## P~~d**•** :tnfoxmatiou Purau&nt to the Cle&D Air' Aot 

### This Request for Informati on revises th e Request for Information that tne u.s. Environmental Protect ion Agency (EPA) issued on February 22; 2008. EPA is requiring Veolia ES Technical Solutions, LLC (Veolia or you) to s ubmit certain information about your h azardous waste incine rators at I 

### Mobile Avenue, sauge t, Illinois

. Appendix B specifies the information that you must submit. You must send thi s information to us accordin9 to the schedule in Appendix B. we are issuing this information request under section 114lal of the Clean Air Ac t (ACt), 42 u.s.c. § 

### 1414la). Section 114(a} authorizes

. the Administrator of EPA to require the submiss ion of

. information

. The Administrator has delegated this au t hority to t he Director of the Air and Radiation Division, Region 

## s. 

## ·. veolia owns and operates thre e hazardous was te incinerators at its Sauget, Il linois , facility. We are requesting this information to determine whether your emiss i on sources are complying with the National Emission Standards for Hazardou s Air POllutants from Hazardous Waste Combustors, 40 C.P.R. Part 63,

## SUbp~rt BEE (hereinafter, •the HWC MACT"l and to establish the appropriate operating parameter l imi ts for each incinerator. You must send all required information to:

VES 004721

### Attn: coropliance Tracker , AE-17J Air Enforcement and corrpliance Assurance Branch · U

. S

. Environmental Protection Agency Region 5 77 

## w. Jackson Boulevard, AE-1 7J Chicago, Illinois 6060 4 With copies to Illinois Environmental Protec t:lon Agenc y: Ray Pilapi l , Manager Compliance and Enforcement Section Bureau o f Air Illinois Environmenta l Protection Agency 1021 North Grand Avenue Bas t Spr ingfi e ld, Illinois 62702 And M

i chael Reed, un i t M anager Clean Ai r Act Permit Program Bureau of Air Illinois Envi ronmental Protection Agency 1021 N orth Grand Avenue East · Springfield, I l l inois 62702 Y

ou may consider the information confidential that you

## ~~it to u s. You may assert a claim of business confidentialit y for any portion of the submitted information under 40 C.P.R

. Part 2, Subpart 

### B. Appendi

. x A specifies the assertion and
subs tanti ation requirements for business confidentia lity claims. Veolia must submit all requested information under an aut horized signature with t he following certi ficat ion:

. I certify under pen a l t y of law that I have examined and 

### am famili a r wi t h the

### nf**ormati on**  in the enclosed documents, inc luding al l att a chments

. Based

. on my 

### inquiry of those i ndividual s with pr i mary responsibility for obtaini ng the info rmat ion. I certify that the stat e m ents and information a re. to the best of rrry 

### know ledge and belief, true and compl e te. I 

### am aware that there are significant penalties for knowingly submitting false statements and information, including the possibility of fines or imprisonment pursuant to section ll3(c) (2) 

### of the Act, and 18 

## u.s.c. §§ 

### 1 001 and

. 13 41.

We rMY use any information submitted in 

### res;>onse to this requ e st in an admini st rative, civil, or criminal e nforcement 2

VES 004722

### action. This request is not subject to the· Paperwork Reduction Ace, 44 

## u.s .c . § 

### 350l

. et seq., because it seeks collection of information fro m a speci fic e nt ity as part of 

### an adminis trative action or inve stigati o n. To aid in our electroni c r e cord keeping efforts , please provide your response to this reque st for information without staples. Paper clips, binder clips , and 3- r ing binders are a cc eptable. Fai lure to comply fullY with this request f or information may subject veo lia to an enforcement action under section 113 of t h e Act, 42 

## u . s.c. § 

### 74 13

. You s hould direct any questions about this request for i n formation to Charles Hall at (312} 353-3443

.

recto r and Radiation Division

3

VES 004723Appen4lx A Confidential BUaineaa Znfoxwation (CBZ) Aa aertion and SUbatantiation Requi r-.ota 

### A. Assertion Requirements You may assert a business confidentiality claim covering all or part of the information requested in the atta ched l ett er , as provided in 4 0 C.F.R. § 

### 2.203(b). To make a confidentiality c l aim, submit the requested i n formation and indicate that you are making a claim of confidenti ality

. Any document over which you make a cl aim of c onf identiality should 

### be marked by attaching a cover sheet stamped or typed w i th a l egend to indicate the intent to claim confi dentiality. T he stamped or typed l egend, or other suitable form of no tice, should employ l anguage su ch as •trad e s ecr et• or • p r opri etary• or •c ompany co nfidential" an d indicate a date if any w h en the i nf ormation should no longer b e t reated a s confidential. Information covered by suc h a cla im wi ll b e disclosed by 

### the EPA only to the extent permitted and by means of the procedures set forth by 

### Section 1 14 ( c) of the Clean Air Act (th e Act), and 40 C.F.R. Part 2. Allegedly confidenti al porti ons o f o t herwise nonconfidential documents shoul d be clearly identified. EPA w il l construe the failure to f urn i s h a confidentiality claim with your response to t he a ttached letter as a wa i ver of that claim, and the informati o n may be made a vail able to th e public without further noti c e t o you. Please segregate personnel, medical and similar file s from your responses an d include that informatio n o n s eparate sheet( s ) nar ked as "Per sonal Privacy Informati on• given that disc lo sure of such informati on t o the general public may constitute an invasion of privacy. B. Substanti a tion R equire ments All confidenti al it y claims are subject to EPA v e rification and mu s t be made in a c cordance with 40 C.F.R. § 

### 2. 208 w hich provi d es in part t hat you satisfactori ly show tha t you have taken reasonable mea s ures t o protect th e**co fi~entia** **it y**  

### o f the information an d that you intend to continue t o do so; and t hat the i n fo rmation i s not and has n ot been reas o nably obtainable by 

### leg itimate means without your consent. Pursu ant to 40 C.F.R. P a rt 2, Subpart B, EPA. may a t any time send you a le tter asking you to substantiate fully y our CBI claim. If yo u re c e ive such a l e tte r , you must provide BPA with a response withi n the number of days s et forth in the E PA request l etter. Fai l ure to submit your comments within that t ime wou l d be 

### regarde d as a waiv er of your confidenti a lity c la i m or c l a i ms , and EPA may r e le as e the informat i on. If you rec e i ve such a

VES 004724letter, EPA will ask you to specify which portions of the information you consider confidential. Y-ou au a t be apeoifio by page, paragraph, and aantanoa when**ident~fying** tha**1nfo~tion** auhjeot to your claia. Any informacion not specifically identified as subject to a confidentiality claim may be disclosed to the requestor w ithout further notice to you. For each item or class of i n formation that you identify as being subject to CBI, you must answer the following questions, g i ving as much detail as possible: · 1. For what peri od of time d o you request that the information be mai ntain ed as confidential, e.g., un ti l a certain d ate, until the occurrence of a s pecif i ed event, o r permanently? If the o cc urrence of a s pecific event will eliminate the need for confidenti a lity, please speci fy that event. 2

. Info rmation submitted to EPA becomes stale over time. Why should the information you cla i m as confi dential be prote c ted f or the time pe, riod specified in your answer to qu e stion tl? 3

. What measure s have y ou taken to protect the information claimed as confidential? Have y ou disclos ed the informat ion to anyon e other than a g overnmental body or someone who is bound by an agreement not to disclose the inf ormation furth e r? If so, why s hou ld the information still be consi d ere d confidential? 4

. Is the information contained in any publicly avail able materi al such as the Internet, pub l icly available databases, promotional publicatio n s , annual reports' , o r articles? Is there a ny m e ans by whi ch a member of the publ ic could obtain access to the information? ls the informati on of a kind tha t you would customarily not release to the public? 5. Has any governmental body made a determination as to the confidentiality of the information? If so, please attach a copy . of the determination. 6

. Fo r each category of information claimed as**conf~dential,** exp lain with specifici ty why r el eas e . of the**in fo** **rrr~tion** is li kely to cause substantial harm to your competitive position. Explain the specific nature of those harmful effects, why they should be viewed as substantial, ond the causal relat ionship between disclosure and such harmfu l effects. How coul d your compet itors make use o f th i s information to your detriment? 7. Do you assert that the information is submitted on a 2

VES 004725**v~luntary** 

### or a mandatory basis? Pl e a se explain the reason for your .,saer ti on. If you assert that t he information is voluntari l y ' submitted i nf orma t ion, explain whether and why d i sc lo s ure of t he i nformation would tend to le s sen the availability eo EPA of s imilar info rmation in the fu tur e. 8

. Any other issue you deem relevant

. Ple ase note that emission data provid ed under Section 114 ·of th e Act, 42 

## u.s.c . § 

### 7414, is not entitled to confidenti a l treatment under 40 C.P.R. Part 2

. "Emission data• meane, with reference to any source of emiss i on of any substance into the ai r - Informati on necessary to d etermine the i dentity, amount, frequency, conc en tra tion, o r other characteristics (to the extent r e lated to air quali ty ) of any emission which has been emitted by the sour ce (or o f any pol l u tant re sul t i ng from any emiss i on by the sour ce), or any . combination of the foregoing; Inf ormation necessary to determine the identity, amount, frequ ency, c onc entrati on, or other characteristics (to the ext ent re lated to air quality) of the emissions w hich, under an applicab l e standard or limitation, the sourc e was · authorized to emi t (including, t o the extent necessary for such purposes, a description o f the manner and rate o f operation of the source); and

. A general de s cription of the locati on and / o r nature of the

source to the extent necessary to i dentify t h e sourc e and to distinguish it from other s ources (including, to the extent nece s sary for such p urpos es, a d e sc ri ption of the device. installati on, o r operation cons ti tu ting the source)

. 40 C

. P. R

. § 

### 2.30l(a) ( 2) ( i) (A ), (8) and (C). Emission data 

### includes , but is n ot limited to, servic e records sta ting the amount of refri ger an t added to a unit o r reclaimed from a unit

. If you receive a request for a substantiation lett er f rom the EPA, you bear th e burden o f substan tiating your confidentiality c la im

. Conclusory al l egations will be giv en little 

### or n o weight in the de t erminati o n. In substantiating y our CBI claim(s) , you must brac ket all t ex t so claimed and mark i t 'CBI

. " · Information s o designated wi l l be d is c losed by EPA only to the extent allowed by, and by 

### means of the procedures set forth in, 40 C.P.R. Part 2, Subp art B. If yo u fail t o cl a im the 3

VES 004726informat io n as ·confidential, it may be made

. avail ab le to 

### the pwol1 c without f urther notice to you .

4

VES 004727Al'P BNDIX B Veolia must submi t the following information regarding Incinerator 2, Incinerator 3, and Incinera tor 4 l ocated at 7 M obile Avenue , Sauget, Illinois in accordanc e with the foregoing request for information made pursuant to Section 1 14(a) o f the Clean Ai r Act , 42 

## o . s.c . § 7 4 1 4 (a). 1. T h e February 22 , 2008, Section 1 14 Requ e st required Veolia to submit to EPA a plan to conduct a comprehensive performance tes t on eac h 

## of i t s three hazardous waste incinerators. The requirements pertaining to the test pla n content and options (I t ems 

### *2, t3 , * ' · and

. i6l remain in effect. 2. No l a ter than August 15, 2008, Veo1ia must commence a performance test for lo w volatil e m e tal s ar s enic, beryllium, and c hromium (LVM); semivolatile metals cadmium and lead (SVM); and m e rcury for eac h h a zardous w a ste incinerator at its Sauget, IllinOis facility. veolia must co. nduct three test runs of Reference Method 29 in 40 C .F .R

. 60, Appendix A on each incinerator. The minimum sample vol ume for mercury s hal l be 1.7 cubic meters. V e oli a must complet e the p erformance test on each incinerator within 15 days of cormnencement
. ). No later than 10 days b efor e Veolia commence s t h e performance tests for each incinerator, Veolia shall notify EPA and Illinois EPA o f t h e s cheduled start date. 4. veo l ia must collect suffic i ent data to esta b l i s h all m ercury, LVM, and SVM operating pa r ameter limits (OPLs) set forth in 4 0 C.P.R. §§ 63.1209(1) through (n) of t ho HWC MACT. E P

A beli eves that the following OPLs set forth in 40 C.P.R. § 63

. 1209(11 through (n ) apply t o each inc in erator :
a . Incinerator 12 63.1209 HAP' OPL (1 ) ( 1 ) (i) Mer c ury Maximum M ercury Fe e d Rate (o) (1) SVM, LVM Maximum Pabric Pilte r Inlet T em perature (n) (2) (ii l SVM Maximum SVM Peed Rat e ( 0) (2) (ii) LVM M a ximum Total LVM Feed Rate (o) (21 (vi) LVM Maximum Pumpabl e LVM Peed Rate ( 0) ( 3)' SVM, LVM Representative and reliable indicator (m) (i) (iv ) o f P M control d e vice performance ( n ) ( 4 1 SVM , L VM Maximum HC1/Cl 2 Peed Rate
1 RAP • hazardous air pollutant.

VES 00 4 72 863.1209 OPL (n) (5) S VM, L VM Maximum Flue Gas Flow Rate b

. Incin era t or t 3 63 .1 20 9 HAP OPL (1) (1) (i) Mercury Maximum M ercucy Feed Rate (nl (1) SVM , LVM Max imum Fabri c Filter Inlet Temperature (n) (2) (ii) SVM Maximum SVM Feed Rate (n) (2) (ii) L VM Max imum Total LVM Fe ed Rate (n) (2) (vi) LVM Maximum l e LVM Feed R a te (n) (3). SVM, L VM R epre sentati v e a nd r e li ab le indicator (m) (1) (iv) of PM control d e vic e £er forman c e (n) ( 4 ) SVM

. LVM Max imum H Cl/Cl 2 Feed · Rat e (n) (5) SVM, LVM Maximum Flue Gas Flow Rate
c . Incinerator i 4 63

. 1209 HAP OPL (1) (1) (i) M ercury Maximum M erc ury Feed Rate ( 1)(3)

. (.k) (5). M ercury, Repre senta tive and r eli abl e indicator (m) (1) Civ). SVM, LVM of PM control d evice performance (nl (3) (1)(3) ' M ercury Minimum carbon i njection r ate (.k) (6) (i) (1) (3}. Mercu r y Minimum carrier f l u i d (gas or liquid) ( k ) (6) (ii ) f low r ate o r pressur e drop

_ (1)(3)

. Specify and use the brand (i.e

. ' (k) (6) (iii) Mercury manufa ctur e r ) and t yp e of carbon u s ed (A) during the mercury p arformance tes t (n) ( 1) SVM, LVM Ma

. ximum Fabr ic Filte r Inle t Tempera ture (n}(2}(ii} SVM Maximum SVM Feed Rate (n} (2) Cii) L VM Maxi m um Total L VM Peed R ate (n) (2) (vi) LVM Maximum Puaq;>able LVM Feed Rate (n) (4) SVM, LVM Maxim um H Cl/Cl 2 Fe ed R a te ( n ) (5) SVM, LVM Maximum Flue Gas Flow Rate Veoli a is responsibl e for identifying any additiona l appli c able mercury, LVM , a nd SVM OPLs . ·**~.** During the per formance t e sts on eac h i n cinerat or. V eolia sha ll collect compos i te samples of a ll waste streams that it feeds t o t he incinera tor
. Veol i a s h a ll analyze the composite samples for mercury, arsenic, beryll ium , chromium, cadmium, lead, a s h, a nd total chl ori ne . 6. Durin g the p erformanc e te at s on e a c h i nc in erator, Veolia 2

VES 0 04729

### must feed normal (or higher) l evels of ash and chlorine during the performance t ests , 7. During the performance tests on each i ncinera tor, Veolia must conduct the SVM and LVM performance te sts when the PM control device undergoes its normal (or more frequent) cleaning cycl e . Veolia must record the times and durations of the cleaning cycles during the performance teat and include the cleaning cycle data in the teat report
. 8. Because Veolia must establish limits for the applicable operating parameters specified in § 

### 63.1209(1-n) based on operations**~uring** 

### the performance tests, Veolia may conduct testing under two or more operating modes to provide oper a ting flexibility. 9

. No later than September 26, 2008, Veolia

.must submit the m

e rcury, SVM, and LVM portion of its Notificat ion of Coa-q;>liance (NOC)

. The NOC must document coa-q;>liance with the emission standards and continuous monitoring system (CMS) requirements, and identify the mercury, SVM, and LVM OPLs under 40 C.F

. R. § 

### 63.1209. The NOC shall include :
a. 'l'he methods that were used to determine col'l\)liance; b. The results of any performance tests, CMS performance evaluations, and/or other monitoring procedures or methods that were conducted;
c. The methods that will be used for determining continuing compliance, including a description of monitoring and reporting requirements and test methods; d. The type and quantity of hazardous air pollutantll emitted by the source (or surrogate pollutants if specified in the r elevant standard), reported in 

### units and averaging times and in accordance with the test methods specified in the relevant standard; and
e. A statement by 

### the owner or operator of the a ffected existing, new, or reconstructed source as to whether the s ource r£s complied w ith the relevant standard or other requirements: 10. Upon postmark of**the~~.** 

### you must comply with all operating requirements specified in the NOC in lieu o f the limits spec if ied in the DOC required under S 63.12ll(c). 11. No later than September 26, 2008, Veolia mu s t submit a 

### report for the performance tests. The test report must 3

VES 004730

### include the following information : a. the raw s ampling and analysis data; b. the anal yses of samples; c . an eJ<.ample of each calculation performed; and d. the 1-minute averages for each operating parameter. 12. No later than september 26, 2008, veolia must submit to EP!\ an application for a significant modification to the Part 71 permit to incorporate the OPLs identified pursuant to paragraph 9, above. 13. Provided that the results of these performance tests result in data that meet quality assurance objectives such that the results demons trate compliance with the applicable standards, are sufficient to establish the applicable OPLs under 40 C.P .R. § 

### 63.1209, and meet all requirements of 4 0 q.F.R

. § 

### 63.1207 for conducting comprehensive performance tests (CPT), these performance tests will serve as the mercury, SVM, and LVM portion of the c
. FT 

### required between

· october 1 4 , 2008, the compliance date for the standards set

forth in 40 c . F.R. § 

### 63.1219(a) and (c), and october 14 , 2009, the date by 

### which veolia is otherwise required to conduct a CPT on each incinerator.

VES 0047 3 1

### CERTIFICATE OF MAILING
I, 

### Lor etta Shaf fer, certify that I 

### sent a Request to Provide Informati on Pursuant t o the Clean Air Act by Certified Mail, Return Receipt Requested, to: ooug las Harris, General Manager Veolia · ES Technical Solutions. LLC 7 

### Mobile Avenue sauget, Illinois 62201

I 

### also certify that I 

### sent a copy of the Request to Provide rnformation Pursuant to the Clean Air Act by 

### First Class Mail to: Ray 

### Pi lapi l , Manager compli ance and Enforcement Section Bureau of A ir Illinois Environmental Protection Agency 1021 

### North Grand Avenue East Spring field , I l linois 62702 

### And Michael Reed, Unit Manager Clean Air Act Permit Program Bureau of Air Illinois Environmental Protection Agency 1021**No~~** 

### Grand Avenue Bast Springfield, Illinois 62702



### on the 

# 5**~** day 

### of

# J~.loU:1..1!.:>~LS-I'---- 2008



### retta Shaffer, AECAS (MN-OH )

Certified Mail 

### Receipt Number: 

### JQO/ Q;.?.Q

# a~ ·r'W'l !61/'1

VES 004732ste.ndard bCC ' S:

other bee' s :

c reation Pate: Filename: Legend: Official File Copy w /"enclosure(s) Section Reading Pile w/o enclosure{s) Branch R eading Pile w/o enclosure{a) J. Woolums,**C~l 4J**  June 4, 

### 2008 C:\EPAWORK\WasteCombuscion\hazwaste\Sources\ veolia\ll4LetterRev.dOc ARD:ABCAB:AECAS(HN/OH) :c.hall

VES 004733

## VES 004734

. pdf:

UNITED STATES ENVIRONMENTAL PR OTECTION AGENCY REG ION 5



## JUN 12 ZOOS CERT JiilED MAJL 

### n WEST JACKSON BOUlEVARD CH I CAGO , ll 60604-3590

REA.V TO lltE A namoH Of';: AE-17J
RETURN RECEIPT REQUESTED Doug Harris General Manager Yeolia Bnviroumcotal Services 17 Mobile Avenue Sauget, Dlinois 62201 Dear Mr

. Harris: This is to advise you that the U. S. Environmental ProteCtion**A~ency** has determined that Veolia Environmental Services' facility at 117 Mobile Avenue, Sauget. illinois is in violation of the Clean Air Act (CAA)

. We are today issuing you a Finding ofViolation (FOV) for these violations. The Act requiTes the development of standards for emissions of Hazardous Air Polluwrts (HAP ) to protect the public bealtb and welfare. EPA has promuig;lled Maximum Achievable Cont rol Tecbnology (MACf) standards set forth to address HAP emissions from various SO\UCc categories. As discussed more fully inthe enclosed FOV, Veolia is in violation ofthe MACT standards that regulate HAP emissions from Hazanloas Waste Combustors. Section 113 of the Act gives us several enforcement options to te$0lve these violations. The options include issuing an administrative compliance order, is.suing an administrative peoalty order , bringing ajudicilll civil action, and liringing ajudicial criminal action. We are offering you the opportunity to request a oonfercnce with us abo ut the violations alleg ed in the FOV

. This confcreoce will give you an opportunity to present information on the specific findings ofviolation, any efforts you have taken to comply, and the steps you will take to prevent 1\atwe violationr

. Please plan for your facili ty' s technical and management persomtel to tske part in lhesc discussions. You may have an attorney represent you at this conference.

VES 0047342 The EPA contact in this matter Is Sarah Marshall. You may call her at (312) 886-6797 to request a conference. You should Jllllke the request within I0 calendar days followin,g receipt of Ibis letter. We should bold any conference within 30 calendar days following receipt ofthis letter

. ·

Enclosure Sincerely,

Cheryl L. Newton ACting Director Air and Radiation Divi5ion

cc: Ray l'ila pil, Manager Compliance and Systems Management Section Ulinois EnvitOIIlllental Protection Agency

VES 004735. United Stotes Eovlroomcotol l'rotectioo Agency**~THE** MATTER OF: t.reolia Environmental Services fJNDING OF VlOLATION gsJ>uisuanllo \EJ'A-5-08-19-IL }he Clean Air Af:;t,**~2** 

## u.s.c. §§ 7403 d seq.

liJNDl NG OF VIOLATION Veolia Environmental Services (you or V coli a) owns and operates three hazardous waste incinerators at

# 7 Mob ile Avenue, Sauget, Dlinois (facility). The incinetaton are identified 

### a.s Incinerator Nos. 2, 3, aru14. Tho U.S

. Environmental PrOteetioa AgoriJY is seudiug you this Find ing ofViolation (FOV) to notify you that we have foUDd lllatVeoliz is violating Se<:lioo 112 of!he Clean Ali Acr. and i ts iinptemeoting regnla!ions for Natiollal Emission Standmds fOr Hazm1ous Ali Pollutants liom HazardOUS WI!M CombustOrS at 40 C

. P.R

. Part 63, Subpart EBB. National Emission Standards for Haurdoua Air Po llutants fro m Hazardous W aste Comb v srors

I. On September 30, 1999, U.S. BPA promulgated the National Emission SWldards for Hazardous Ali Pollutants from Hazardous Waste Combustors (a.WC NBSH.AP) at 40 C .F.R. Part 63, Subpart EBB (64 Fed. Reg. 5303 8). 2. In July 2001, the D.C. Circuit Court of Appeals vaca ted lhe HWC NESHAP

. 

### Cement Recyclillg Coal

. v. EP A , 347 U

. S. App. 'D.C. 12 7 ,25 5 F .3d 855 , 857 (D.C. Cir. 200 1)

. The Court stayed the vacatUT until U.S. EPA could promulgate interim standards· 3

. On FebruarY 13,2002, U.S

. EPA promulgated the HWCNESHAP interim $lllndardS at 40 C .F.R Part 63, Subpart BEE (67 Fed. Reg. 6792)

.

VES 0047362 Regu latory Require ments for HWC NESHAP 4. The following HWC NBSHAP requirements are relevant to this FOV:
a. 40 C.P.R. §63.1203(a)(2) prohibits a source from emitting mercury in excess of 130 micrograms per dry &tandard cubic m eter (ug/dscm) for all hazardous waste incinentors. b. 40CF.R. § 63.1207(bXl} requifes that 

### m owner or operator 

### ora Hazardous Was.e Combustor conduct 

### a Comprehensive Perfoanmce Test to, in part, dmlOD.Strale compliance with the HWC NBSHAP emission standards and establish operating 

### parameter llmil$.
c. 40 C.F

. R. § 63.1207(1) requires 

### a source to submit 

### a Compliance Performance Test Plan. d. 40 C.F.R

. § 63.1207(f)(l)(x) states that if a sowce w ants to reques t to extrapolate meta l feed rate limits frQm the Compliance Perfonnance Test l evels, it must include tbc following in the Compliance Performance Test Plan: i.

. A description ofthe extrapolation methodology and rationale for how the awroach ensures COIIlPiiance with the emissions &Wldards; ii

. Documentation of the historical range ofnormal (i

.e., other than during compliance testing) metals feed rates for each

### fe~am; and iii. Documentatioo that the level ofspiking ROOmrnended during the performance 

### test wiD m.U sampling and analysis Unp=irion and inaccuracy to the e.xteot that lhe extrapOlated feed rate limits adequately assure compliance wilh the emission standards

. Expboatlon ofViolatioa S

. From at least January 2005 through March 2006, ¥eolia's mercury emissions exceeded 130 micrograms per dry standard cubic meter at Incinerator Nos. 2, 3, md 4 in violation of40 C.P.R. §63.1203(aX2)

. 6. From at least December 30,2003 lhrough lhc present, Vcolia bas used and continues to use as surrogstes for mercury emission standards operating parameter limits lhat it derive<! funD an extraQOiation melhodology for which it did not aoorooriatelv..=uest 

### approval in its eou®iance Performance Test Plan. iD VlOlallon or40 I;J'.I{. § 63.l207(f)( 1 

# x

xr

VES 0047373 E

n vlroameatal Impact ofVl ol a tloa• 7

. Ha7.aJ:doUS Air Pollutant (HAP) standaxds may cause serious health effects inolodU:ig birth defects and cancer. HAPs may also cause harmful environmental and ecological effects.

ActingDi=r Air and Radiation Division

VES 0047 384 CERTIFICATE OF MAILING I, Betty Williams, certify that ! sen t a Notice and Finding ofViolation. No. EP A-5-08- 19- lL, by Certified Mail, Retutn Receipt Requested, to: Doog

. Hal:ris 

### General Manage< Veolia Euvironmental Serviees #7 Mobile Aven ue Sauget, lllinois 62201 I also certify that I sent copies of\he Finding ofViolation and Notice ofViolation by lUst

c l ass ma il w: Ray Pilapil, Manager Compliance and Systems

### Manageu~ent Section nlinois Bnvironmelltal Protection Agency 1021 North Gran d Avenue Springfield, Dlinois 62702

on tbis

# ~yof**~** 2008

VES 0047 39

## VES 0047 40

. pdf070908a
1

1 2 3 4 5 6 7 PUBLIC HEARING and COMM£NT PERIOD CO/KERNING EPA'S PROPOSAL OF A ORAFT OPERATING 8 PERMIT FOR VEOLIA EHVIRONMENTAL SERVICES 9 10 HELD O N: Ju l y 8, 2008
11 12 13 14 15 REPORTER: sara E. Tipton, CSR ILLINOIS NO: 084-003397 16 17 18 19 20 2l RIV ER BEND REPORTING CERTIFIED SHORTHAND REPORTERS 22 P.O

. BOX 577 GODFREY, lL 62035 23 618-466-8558 24 25 0 2
Page 1

V E S 0047400 1 2 3 4 5 6 7 8 9 10 

## u 12 13 l4 15 16 17 18 19 20 2l 22 23 24 070908a MS. POPE: we're going to get read y to start the public hearing. Hello again, everybody. 

### MY name is Janet Pope, and I'm a community

### In**vo lve~ent**  coordinator for the US environmental Protection Agency. Tonight 1 will be serving as your hearing officer for tonight's public hearing. 

### we have two other people from t h e US Envirorwenul protection Agency here tonight. we have Genevieve oanri co, who i s an Envi

### ro~~~>ental Eng i neer with the 

### us EPA. we a l so have charlie Hall, who is an envi

### ron~~~ental engineer al so. everybody is with the us EPA, and we're out of chicago, Illinois. we are here tonight to share information, to listen to your questions and comments regarding EPA'S proposal of a draft-operating permit for the veolia environmental services 10cated in sauget, Illinois. Tonight's hearing wnl have three parts. The first part Genev i eve oamico will provide an overview of the draft permit. sec ond. we will take your connonts for the record, public connents for the record; and, third , if tiooe a11 ows, we w i 11 have an i nfoi'JI3l question-and-answer period. Now, when you came in, there was a sign-in sheet in

25 the back. 1 hope everybody signed in. what that does is revises our mailing list, and if there's any

### infor~tion coming up regarding the site, you'll get the information.
3

1 so sign in if you want to get information regarding the 2 site. 3 with the excepti on of the i nforma1 4 question

- and-answer period, everything .rill QO on record. Page 2

VES 0 04 7410 5 6

· 7 8 9 10 ll 12 13 14 15 16 17 18 19 20 21 22 23 24 25 070908a we have a court**epo~er** to my right

. she'll be recording this meetin g in its entirety with the exception of the informal quest ion-and-answer period. All persons wishing to speak tonight, when you signed in, I hope you checked the oo vou Plan to Make comments, there is a yes -or-no box. If you want to make formal comments, check the yes box. okay. And then we did have people call in previously and sign in an d make an appoi n tment, too, so those people w ill be called first, and the people that s igned jn today, you'll be fi l led in in the slots that we have vacant
. okay. Now, Genevieve I'l l have her come up, and she'll give an overview on the draft-operating permit. MS

. DAMICO: Good afternoon, everybody. A

. 

### . quick overview of the action that we' re tal king today. The veol i a Environmenta l

### Techni~al services from sauget, Ill inois, is a treatment, storage and disposal facility, which accepts offsite w aste for further disposal through incineration. container s and bulk shipments of hazardous and solid wastes are received, analyzed and transferred to tem porary storage facilities, processed and
4

1 incinerated in one of three combustion units. 2 veolia is located in an area that is attaining all 3 of the national amb ient air-quality standards except for 4 both the eight-hour ozone and particulate matter less 5 than 2.5 m icrograms standard. 6 veolia requires a Title v permit because it is a 7 major source of hazardous air-pollutant emissions subj ect Page 3

VES 0047420 8 9 10 ll 12 13 14 15 • 16 17 18 19 20 21 2

2 23 2

4 070908a t o requirements under section 112 of the clean Air A ct for boi l ers and hazardous waste cOMbustors

. Title v of the clean Air Act requires , in part, that all major sources subject to st andards under s ection 112 oP.erate in accordance with a permit

. MOst Ti tle v operating permi t s are iss ued by state or local permitting authorities. EPA is issuing this permit because in response to a petition f rom the sierra club and the American Bottom conservancy, EPA objected to the permit proposed to be issued by the Illinois E P

A. under Titl e V; whe n EPA objects to the proposed permit, the state permitting · authority has the opportu n ity to address EPA's concerns , but if EPA ' S concerns are not addressed in a t · imely fashion, then EPA becomes responsible for issuing or denying the permit.

25 In this case, I llinois EPA did not respond to EPA's concerns in a t i mely manner, and on september 29th, 2006, EPA announced i ts intent to issue or deny veolia a


## s

1 federal Title v permit. veolia submitted its application 2 to EPA on May 2nd , 2007. EPA deemed the application 3 administratively comp l ete on June 13th, 2007. 4 Pursuant to a proposed settlem ent agreement betw een 5 E PA and the sierra club and the Amerlcan Bottom 6 conservancy, EPA intends to

### co**~plete** the public comment 7 process by J uly 18th, 2008, and issue or deny a final 8

. permit by september 12th , 2008. 9 concurrently with this permitting process, EPA has 10 alleged that veolia is in

### nonco~liance with the clean 11 Air Act. NOthing in this permit w ill shield veolia from Page 4

V ES0047430 070908a 12 any enforceme nt action related to past or ongo1ng 13 violations that we have alleged

. 14 EPA has in cluded a compliance schedule in the draft 15 pe rmit that requires veolia to test all three combustors, 16 to develop operat i ng parameter li mi ts for emissions of 17

### ~ercury**,** low-volatile metals and semi

- volatile metals as 18 required by the hazardous waste combustion MACT. The 19 draft permit requires that veolia submit the results of 20 this testing and revi sed operating parameter limits by 21 september 26 , 2008. 22 If veol ia finds

-- or I ' m sorry -- if EPA finds the 23 revised operating parameter limits acceptable, EPA will 24 r eopen the permit to propose inco rporating the operating 25 parameter li mits developed from th e requ ired performance

1 test into the f1nal permit and solicit public comment on 2 the incorpo ration of the operating parameter limits into 3 the permit. I n addition, the permit may be reopened at a 4 future time to incorporate additional applicable 5 requirements or compliance schedul es. 6 MS. POPE: EPA'S public participation 7 regulations require EPA to publish a public notice in the 8 local newspaper. The public notice appeared in the East 9 st. Louis Mo n itor and the Belleville News Democrat, both 10 published on June 5th

. In addition, information was 11 mailed to those who attended Illinois EPA public hearing 12 for veolia and the h ear 1 ng for veolia's ne i ghbor, 1 3 solutia. Now,

### ~<e'll beg i n our public co1111ent period. I will Page S 14

VE S 0047 440 070908a 15 call t he spea kers in the order

-- not on th e sign

- up 16 sheet but on th e sign- u p sheet mixed in wi th t he calls 17 that we already h ad. when your name is ca l l ed, please 18 state your naMe; then spe ll your la st name for the court 19 reporter. If you have wri tten

### co~ment**s** but do not w ish 20 to speak t oni ght, please give them to me before you l eave 21 ton i ght. so that everyone 

## vmo wishes to speak has a 22 chance to do so, limi t your comments to five minutes . If 23 you cannot f inish , I will ask you to p l ease conclude. A t 24 five minutes I wi l l ask yo u to please conclude your 25 conment s. At t hat time you will wrap up in the next
7

1

### ~inute**.** okay. Five mi n utes I 'll ask you to conclude

. 2 vou have a mi nu te to fin ish. okay. At th e s i x-., inute 3 i n terval I w ill ask you to rend er the fl oor to the n ext 4 speaker. okay. All right. After everyone has gotten a 5 chance to speak, you may return and finish your coe4ents, 6 or you can subMi t your remaining comments on paper. 7 Now , 

### we w ill begin our p ubli c

### co~nt per io d. 8 Remember , if you have written

### c~**ents ,**  give them to me 9 before you leave to day. If not, we 'll start with our 10 first speaker, and I have a cordl ess here s o I can run 11 around and get you. Livi Isringhausen

. 12 M S

. tSRI N G

HAUSEN : Good afternoon. I 'm L i vi 13 I s r i nghaus e n , I·S- R ·I·N

- G·H

- A·U·S·E·N. I'M the 14

### nviro~ental compliance Man ager at Washington University 15 in 

### st
. Louis school of Medicine

. washington university school of Medicine is rated as one of the top f iv e

### ~edical schools in the nation by 

### u s News and wo rld 16 17 1 8 R eport
. we have 

### a hundred and sixteen year history of Page 6



## ves o 047 4

5070908a 19 research and education. one of the best things that 20

### c~es out of the university is our research

. we receive 21 grants and contracts in excess of 460 million dollars In 22 research effort for medicine alone. 23

### so~e notable things that have come out of our 24 research are that we have done extensive research and 25 development in looking for a cure for Alzhei•er's 0 8

1 disease. we helped pioneer the use of insulin in the 2 tre atment of diabetes. we proposed the practice of 3 taking aspirin to prevent heart attacks. we developed a 4 cure for Hepatitis 8, if it was diagnosed early. 

### we 5 found a surgical cure for arterial fibrillation and 6 helped pioneer cochle ar implant surgery. 7 As a result of all this re. search, there are people 

### 8 like myself that 

### work behind the scenes. 

### MY department's 9 responsibilities include the disposal of t he byproducts 10 of this research. washington university has chosen to ll partner with veolia Environmental T echnical services to 1 2

### acco~**ish** the proper and safe disposal of these 13 byproducts. 14 veol ia provides us outstanding service in disposing 15 of our common materials and anything unusual that may be 16 a result of the research. Their knowledge and expertise 17 is invaluable when you come across the many array of 18 byproducts that we generate at the university. Having 19 veolia's incineration complex l ocated here in the 20 S t. Louis / Metro area allows for us, ftany other industries 21 and institutions to reduce our carbon footprint by Page 7

VES 0047 4 6070908a 22 minimizing fuel for transport. 23 In conclusion, veolia has become an i n tegral part of 24 w as hington universitY school of Medicine ' s research by 25 providing us many services. 0 9

1 MS. POPE: Next speaker, Dee Reed. Next 2 speaker I' • going to s ay Dee Reed is not in attendance 3 right now. Put that 

### on the record. GeOrge R. 4 schi1linger. 

## s MR. SCHILLINGER: My**n~e** is George 6 Schillinger, s-c-H-t-L-L-1-N-G-E·R

. I'm the executive 7 Director of the American Bottoms T r eatment Plant in 8 sauget, Illinois. AJnerican Bottoms is-- we operate two 9 plants, phys i cal chemical waste water plant owned by the 10 vi llage of sauget and the regional plant , the American 11 Bottoms plant, which services: East st. Louis, cahokia, l2 Alorton, centreville and a little part of Stookey 13**T~Nnship,** hence, the village of sauget. 14 American sottOIIIS is i1111ediately east of the veolia 15 site and just west of the center ethan ol site on Highway 16 3. You've probably seen it by now. 17 A little bit on

## ~Y background. I have a master of 18 science degree in environmental sanitation engineer i ng. 19 t've done additional course work recently working towards 20 a doctorate. Don't have. 1 teach the capsule and design 21 eng i neering c lass for the environaental engineeri ng 22 program for the students at washington university. Since 23 col l ege, I've worked exclusively in the environmental 24 fie l d

. I'll a registered professiona l enginee r in 25 Illinois.

## 1'~ a reserve officer in the us Publi c Health Page 8

VES 0047470

1 2 3 4 5 6 7 8 9 10 11 12 13 14 1 5 16 17 18 19 20 21 22 23 24 25 0 070908a
10

service with the equivalent rank of a Navy commander. I'm a board certified environmental engineer. Regarding veolia, as I said, they are our next-door neighbor

. I've toured their fa cilities on several occasions and dai ly have an opportunity to observe the operation of th is plant. It's always neat, clean , wellmaintained, odor free, and there are no visible signs of
ai r emissions. The f acil it y i s secure.

### Fr~ the water standpoint or waste-water standpoint, which we enf orce on, t hey are in perfect compliance with o

ur pretreatment program over the year s . MY compliance staff works wi t h veol i a staff and consider them well

- qual ified , very qualified and

### c~~itted to ope rating in compliance with al l environmental regulations and stal:utes. veolia is also an active parl:icipant in the communil:Y· I'm aware th at they provide educationa l tours to local school children and between a -- jointly wi th Ameri can B ottoi!IS an d veolia, we partici pate in providi ng educational programs to the interns in the Illinois Governo r' s**Enviro~•ental** corps. This has been a v ery successful program t o try to train and to encourage co l lege students to enter this fi e l d

. As a knowl edgeable and prof essional environnaental engi neer , I'l!l aware of the nature of t he work at veo l1a
11
Page 9

VES 004 7480 l 2 3 4 5 6 7 8 9 10 ll 1 2 13

. 14 1S 16 17 18 19 20 21 22 2 3 24 25 070908a and their faci li ties and the procedures fo r controll ing ai r emissions and the n ecessary nature o f this wo rk . I am personally qu ite comfortable occup y

i ng an office within five hundred feet o f t hei r f acili t ies and have done so for the p ast twenty-three years . AS the executive director of the AAerican Botto ms, I believe our employees and co ntractor s are not expOsed to any ris k due to the veolia's operation. I'd like to point out that about fifty percent of the AMerican Bottoms customers, which is in the East st. Louis, A

l orton, centreville, cahokia area are below

- - ha ve income le vels below the pOVerty line

. You know, many p

e

ople w oul d argue th a t this is an environmental trust d

ec i sion and

- - and it is

. And it's this way, these are necessary services. In the past three years, Americ an Bottoms has had to raise its rates to a l l o f our cus tomers, including t hese impov

-- and those pe ople below the pOverty line , from Sl .74 per thousand gallons of water discharge to $4.95, and that ' s come about because of the loss of twO aajor i ndustries, Elementis in East st
. L ouis that s hu t d own and went to china and Big River zinc in sauget
. And that's just a substantial b

urden**~\ S.**  POPE: conclude

.**\.** SCHILLINGER : 1 have one more minute.
12

1 That's transferred to the people who l i ve in this 2 community

. 3 I know 1 ' ll finish up with saying veo lia ha . s been an 4 exce)lent neighbor, and I have no fear of working right Page 10

VES 004 7490 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 070908a next door to it. Thank you. 

### Ms : POPE: Next speaker, craig Doolittle. MR. DOOLITTLE: GOOd afternoon. MY name is craig Doolittle , o-o-o-L-1-T-T-L-E, and I have been asked to spea k today on behalf of tHe veoli a ES Technical services in sauget in re gard to the issuance of their Title v permit. First my background. I am a licensed professional ·engineer with over thirtY years of experience in the

environmental fiel d

. I ha ve worked in the hazardouswaste areas since 1980 when the EPA first pr011111lgated the federal hazardous waste regulations under the Resource conservation and Recovery Act

. I n 1983, I sta r ted working in the hazardous-waste combustion area. First as a permit engineer for a l arge rotary kiln combustion faci l ity in region five and then as the operations manager for that facility w here I was responsible for day

. -to-day operations and compliance. In the early '90's I took a national

- level position worki ng with EPA and other stakeholders on the development of more recent combustion regulations under
l3

1 the clean Air Act, the hazardous waste combustion MACT 2 regs , and for the last ten years I worked for ENSR, 3 E-N

- S-R, an environmental engineeri ng and consulting firm 4 where I have designed, written and managed dozens of 5 performance tests under what is known as the Hazardous 6 was t e combustion MACT R egulations and assis ted clients 7 comply with the other provisions of those regulations as Page 11

V ES 004750070908a 8 well. 9 By way of background for ENSR, ENSR is a 2000 10 e mployee global environmental health and safety 11 engineering firm with an air-quality practice here i n the 12 

### us with over a hundred full-time air professional s . I 13 currently manage EHSR'S air source testing department and 14 the i r colllbustion services practice

. In addition to stack 15 testing, ENSR provides: Peraitting, auditing , dispersi on

### l~ modeling, risk assessment and proce. ss engi neering 17 services to clients with

### co~ustion facilities 18 nationwide. over the years , we have worked at a number 19 o f faci l ities here at EPA Region v, and we continue to do 20 so today

. 21 since 2001, I have helped design and manage ten 22 different performance test programs to assist veolia with 23 their efforts to develop sound compliance and operational 24 strategies to cOMPlY with the HWC MACT regulations. In 25 addition, our source testing departlllent has been 0 14

1 performin g the annual relative accuracy testing for 

### the 2 facility's stack-analyzer systems for the last several 3 years as w ell. our source testing staff are all OSHA 4 · HAZWOPER trained and generally have ex per ience levels 5 ranging from 10 to 35 years of experience i n source 6 testing, itself. They are thoroughly familiar with all 7 EPA promulgated test methods. m any of EPA'S test methods · 8 and the alternative methods that are publis hed on EPA'S 9 test method s i t e. ENSR has been in the source-test i ng 10 business for over th ree decades, and the quality of our ll work must be able to be val idated through our own Page 12

VES 0047 5 1070908a 12 internal quality assurance, quality-control systems, 13 through EPA method specific QA/QC requirement s, by 14 independent regulatory agency review and often by third15 party reviewers. our work must be performed to the 16 highest standards. 17 In addition, as a professional engineer, I am also 18 held to a high standard, so when I sign sy name t o a test 19 report, I lllUSt have confidence that that work product is 20 of high quality. The wo r k 

### we have done for veolia is no 21 exception. we have performed all work in accordance w i th 22 EPA methods, us i ng properlY calibrated equip10ent, all 23 test results were reviewed for accuracy and to assure 24 that they met the required

### para~eters for valid testing 25 and the lab results were also reviewed to make sure that 0 15

1 all QA/QC metrics were met as well. veolia has made a 2 significant c01111i tcent to understand the performance of 3 their un i t s at sauget. and I am fully confident that the 4 test results show their compliance with the applicable 5**~c** MACT standards. 6 Finally, in my experience having worked with many 7 different facilities over the years, the sauget facility 8 represents one of the top performers in the industry. 9 Thank you very much. 10 MS. POPE: The next speaker will be R ich 1 1 sauget , Junior. 12 MR. SAUGET: Hel)o**~** name is Rich sauget. 13 Junior,

### ~-u**T.** My resume starts as a resident of 14

### ~he vi l lage of sauget. I'm also the president of the Page 13

VES 0 04 7520 070908a 1S Board of

### Trus**~ees** for the village of sauget
. I'm also 16

### ~he President of t h e school District Board, school 17 oistrict 187 , whi ch serv es: cahokia, sauget , Alo rton 18 parts of Alorton

-- and centreville. And I ' m also the 19 cha i rman of the w ork

### Enforce~nt Investment Board, whi ch 20 is t he five county

### ar~ of st. cla i r county that look s 21 o v

er all work-force issues in t his area. 

### And that's 22 where I'm going to basically start my discus sio n. 23**2~** 2S The area that we - - that we're in right now in the village of sauget is part of, you 

### knaw, a regional area, and the greater area of southwestern Ill i no is is doi"9 16

1 quite w el l in certain aspects, but the ar ea that sauget 2 isn't necess arily doing so well we have high 3 unemployment. w e have quite a few people that are und er 4 the pOverty line, and we have, although a cluster of S i ndust ry within

### ~ village , as well 

### as my n eighbors in 6 c aho kia and East St
. Louis and centreville, that have had 7 s ome tough tiMes bu t are still striving to do well. 8 with veo1 i a and the amoun t of j

. obs that they provide 9 and the community p artn er t h at they have shown

### the~selves 10 t o be is very vital to our economic future for the

- - as 11 f ar as the village is concerned bu t a l so for the peopl e 12 that live in t hat village. 13 And so we 've -- like I sai d , we've had a few bumps 14 in the roads with a coup le of businesses that have had lS some struggles, but we have surviv ed by working together, 16 and with our industrial conmunitY and with American 17 Bottoms, w e've been able to forge through it

. so to be 18 able t o hav e the opportu ni t Y to keep those jobs in the Page 14

VES 0047 5 3070908a 19 area is vital. 20 From the s chool board s t andpoint, we have an ever21 shrinking economic base, which is based upon the property 22 assessment. we've had a co uple

### bu~ps there , too
. A few 23 businesses ha ve left. we have an ever-declinin g 24

### ass**ess~t.** I n working with veolia, they have, I would 2S say , done th eir par t in the barg ain , as far as keep t heir 0 17

1

### asses**s~e ts**  where they need to
. They've always been 2 willing to work with the village and the county to m ake 3 sure that they ' re alway s up to date and to make sure t hat 4 they're pay i ng t h eir fair sha re. They also are working S with the schoo l district, as far as working with the 6 chil dren , help i ng w1th labs , keeping equipment up to date 7 or wo rkin g with that equipment and working in the

- - in 8 the la bs to

### ~ke sure that they're up to snuff. 9 They are also working with Archview Econa.ic 10 Development corporation, whi ch is a corporation that is ll

### ~de of it s

### me~ers, which are industrial folks, business 1 2 folks i n the

- - basically the Alort on -- basically, the 13 school dis t rict , ce ntrevi lle Township, and veolia has 14 been a ·found ing m e

m

be r. T hey've worked very, very 15 cl osely w ith the school di strict for t he car eer day , 16 which brings in four to five hundred juniors and seniors 17 every · year working a t GCS stadium to allow the youth of 18 our community to know w hat opportunit ies they have in 19 their area, pl aces**tha~** they drive by that they , you 20 know, twO years ago they had no idea it was even a place 21 where you could get 

### a job. Page 15

VES 00475422 23 the sch ool district. And, finally, talking about the 24 V i llage of sauget, it is a very delicately-balanced 25

### co~ni**y,** as far as its industrial, heavy industrial in 070908a so I see the

-- veolia as a very good partner with

18

1 part, as well as light ind ustrial in others. If any of 2 those parties, you know, leave the table, it aakes things 3 diff icult. S still trying to

### gr~• our declining base, which has seen 6 some tough times. At one time 

### we were a very small 

### 7 community with a very strong tax base; that is not the 8 case anymore, no matter what people ftBY say. 

### we are not 9 vmat we once were, but veolia is keeping us where we are 10 and giving us the opportunities where we have a little 

### we have a nice mix with our Al!erican sottOMs. we're

11 new growth

. l2 we're working toward greener type energy. we opened 13 a green corridor along

### ~oute 3, and the new ethanol plant 14 

### and some of the things that veolia is doing is alloorlng 15 us to have that opportunity. !n working with veolia, 16 x've been very, very satisfied with t h eir openness, as 17 f ar as their books, to be able to ftlke sure that they are 18 keeping their negotiat ·ions fair, as far as assessment
.

. 19 I drive by their facility on a weekly basis, if not

20 dai ly, and I think that they keep it up. I have toured 21 the facility Many, Many times. I'm very, very 22 comfortable with

### th~ in our community, and I know in 23 talking with our residents within my cO!dunity they see 24 thell as '!- partner

-- 25 MS. pOPE: conclude. Page 16

VES 0047550

1 2 3 4 5 6 7 8 9 10 11 1 2 13 14 15 16 17 18 19 20 21 22 23 24 2S 0 070908a 19

MR. SAUGET:

-- not as a foe o r an adversary

### bu~**,** like I said, we're very, very

### comfo~able having

### ~h~ in our community. Let me check my notes. I touched
on our green corddor and the growth of the vi 11 age ha

. s been successful here in the last three or four years, and I think veolia i s a very strong part of that. There's been some revital i zations and taking over some brown fields and putting them back into

- - back into our tax base. we are hop ing that veolia can continue to thrive and join in wi1:h the r ebirth that the village has had to be able to use some of their excess property, hopefully, which was actually given to the

-- t o veolia in its early stages from the village at one time

. so it's been a long partnership, and we hope to continue that partnership. Thank you. MS

. POPE : Did oee Reed ever show up? MS • 0-'MI CO: NO • MS. POPE: we have a space here at this time if anybody

-- di d anybody else sign up to make comments that is here now? MS

. DAmCO: Robert Schreiber. MR. SCHREIBER: S·C

- H·R-E-I · B-E ·R. My name is sob Schreiber. I'm president of Schreiber, vonley Associates. It's an office located in st
. Louis county,
20
Page 17

V E S 0047 5 60 1 2 3 4 

## s 6 7 8 9 10 ll 12 13 14 15 16 17 18 19 20 2l 22 070908a Missouri. Schreiber, vonley Associates has been retained by veol i a to comment on its u s EPA draft Title v permit and to ensure it meets all the requirements outlined in the federal and state laws. we are specialists in combustion o f hazardous w as t e and have worked on Nany air-hazardous waste permits through the united states. I ' m also a professional engineer in Illino i s and Missouri and 34 other states throughout the nation. A 11-ctle bit of my background, I have a BS in chemical engineering f rom the univers i ty of Missouri i n Columbia in 1972

. Af"ter that, I worked with the Illinois EPA in the Air PerNitting section from 1972 through '74. 1 have a long history in air permits. I then moved to the Missouri Department of**~atural** Resources where I was an inspect i on engi neer in 1974, and then I moved up to where I was d i rector of the state 's Air Program in 1978 and held tha-c position unti l 1980. In 1980, I was the Director of Progra

. ms for the State of

### ~lissou**i,** and I did that from 1980 to 1985, so I covered both ai r and hazardous waste during that time period

.

23 In 1985, I left state government and formed Schreiber , vonley and Associates and continue to do environmental engineering. As a personal note, I ' m a native of Granite city, Illinois, so I have some fami l iarity with this area . My father was raised i n East 24 25 21

l St. Louis, and my grandparents lived there until the 2 early ' 70's before they passed away. 3 The reason I bring that up I do remember back in the 4 'SO's and '60's going to v i sit them from Granite City to Page 18

VES 0047570 5 6 7 8 9 10 11 12 13 14 15

. 16 17 18 19 20 21 22 23 24 25 070908a East st. Louis, Illinois. and sometimes going on to cahok i a, Illinois. An d during that trip, you

### ·~uld pass the coke oven where it was black

. You would pass a steel m

i ll where it was red. You**~~uld** pass a big hundred acre ope n burning dump where the current speedway currently lies where you had to t urn your lights on during t he day just to be able t o see down the road. You the n went past a packing plant that had a rendering plant t hat really smelled very good and then you -- in East St. Louis. If you decided to go fron East St. Louis to cahoki a and went through sauget , it had a high density of chemical plants that also had very strong odors. During that time period, you very seldom saw a b l ue sky. It just did not exist. And the air was so thick you could cut it vlith a knife; and, quite frankly, the situation has

### ;~proved t reM endously since that time period

. Back in about 1980. Trade waste Incineration was started to do hazardous-waste incineration. Prior to that, there real ly wasn't anyplace for hazardous waste to go, other than the open burn or put into a landfill. And even though East st. Louis does not current l y meet the
22

l current air-quality standards, t h e situation has improved 2 tremendously here since the 'SO's and '60's up until now, 3 and a large part of

### th~t is due to activ ities that hav e 4 been done with the clean Air Act passage , the work that's S been done by the US EPA and also the work that's been 6 done by the Illino's EPA and in taking on a lot of the 7 pollution activities that have occurred in the earlier Page 19

VES 004758070908a 8 time periods. My staff and l have reviewed the 178 page 9 permi t to confirm that all the state a nd federal 10 requ irements have been met. 1 1 The Title 

### v**per~it** application i s supposed to be 

### a 12 one stop s h op docUMent that, basically, ties all of the 13 past instruction permits, all of the current l l1inois 14 regulatio n s and a11 of the curre nt opera t ing permits that 15 they have to abide by and all of the standards so that 16 the facility knows what they have to comply with, the 17 age n cy knows what it has to comply with and the citizens 18 can rev iew that and also determine what the applicable 19 regulations are. 20 The application and draft permit includes limits for 21 the three incinerator s there for such things as visible 22 emissions, which you can see coming from the s ta ck where 23 they have a continuous monitor on it

. sulfur dioxide , 24 carbon mono x ide, which they also have a cont inuous 25 monitor for. A continuous monitor is something like 0 23

1 having your

### spee~eter that i s tied to a recorder that 2 the police can come i n and check w hat you've been doing 3 for the previous times you've documented

. They also have 4 to check for organic emissions or vocs. Th at's got a 5 continuous monitor for it. Also , other pollutants that 6 are regulated such as nitrogen oxi de , other hazardou s 7 pollutions , hydrogen chloride, and then they a l so hav e to 8 show that the incinerator can destroy a 1l the waste they 9 put into i t with a very high degree of destruction. 10 They have operating permit

### li~its and what those 11 01ean is that they have 

### a permit after they do 

### a stack Page 20

VES 004759070908a 12 test t hat 13 M S

. POPE: conclude

. 14 M R

. SCHREIBER: They have t O go through and 15 demonstrate how they comply with a ll t hose particular 16 limits. The draft permit for veo l ia's fac il ity contain 17 the operating constraints and the required t!Jlission 18 controls to achieve the minimization of emissions f rOM 19 the hazardous-waste coMbustors and all associated 20 activities. The draft permit contains provisions to 21 deMOnstrate and docwoent veolia's compliance wi th the 22 permit limits. 23 I t is my personal belief the us EPA has done a very 24 thorough job in writing this permit. It meets both tho 25 i ntent and requirements of the MACT standards, the Title 0 24

1 v perarit t ing requirements, and the clean Air Act outlined 2 by cong r ess in 1990. Thank you very .uch. 3 MS. POPE: Dr. Jed Deets. 4 DR. DEETS: GOod afternoon. I'm Jed oeets and 5 I thank you for the opportunitY to speak today on behalf 6 of veolia and their Title v Air Permit

. A little bit of 1 .,y background. I have a bachelor of mathematics f rom 8 SIU, a ma ster' s degree in leadersh ip from the university 9 of H awaii and a doctorate degree o f edu cation from SIU 10 Edwardsville. 11 I served as a high school and middl e school teacher 12 for seven years, a principal for twO years, an elementary 1 3 superintendent for twO years and the regional 14 superintendent of st. clair county for nine years, Page 21

VES 004760070908a lS regional superintend e n t of sc h ools in st. clair county 16 for five years. 17 A n

d then the reason why I'm here today I had the 18 p rivilege of · serving as th e cahokia u nit school 19 superintendent for years 2000 

### tO 2005 for five years, and 20 it was during my tenure

-- i n fact, MY old boss i s here, 21 future speaker , former mayor of Cahokia, who hired De in 22 that position

. But it was during that tenure as cahokia 23 s uperintendent that 1 had the opportunity to wo rk wi t h 24 veolia and Mr. ooug Harris. 2S I th ink back to MY very first Chamber of CQOderce 0 25

l Meeting when the bu si nesses were invited to meet the new 2 superintendent, and everyo ne came up to give me t he i r 3 busines s cards and wanted to tell me what a valuable 4 educationa l partner they wanted to be, and I carefully 

### S filed all those**ca~ds** away k nowing**fr~** 

### •Y vast 6 experience, that when businesses tell you they want to be 7 an educational partner, they r eally don''t want to be a 8 partner. They want

-- they want you to do good th i ng s in 9 thei r community, and they want to hel p out , bu t I kep t 10 tha t card , and it w as n't a

### ~nth or two l a ter, the n ext 11 chamber meeting , or m aybe I t was even at a K iwanis 12 meeting, Mr. Harris c ame up and said , or. oeets , we want 13 to be a bus iness part ner, an educat io n al partner , what 14 can we do to help your schoo ls. 15 so now that he's asked

### ~Ice**,** I began to pro be and 16 say , wttat is it t hat you can do to h elp cahokia school 17 District, and he l isted off four or five things, and one 18 of them he mentio n ed that was very timely was the Page 22

VES 004761070908a 19 disposal of haza : dous waste because the state o f Illinois 20 has very strict guidelines for schools on the 2l ident.ificati on of toxic waste and d isposal of that

. And 22 we were struggling as a school district on how we were 23 going to dispOse of that. And he, Mr

. Harris, said no 24 problem; we'll have staff members come out and work with
25 your science teachers and other teachers, and within two 0 26

1 weeks all of our toxic waste had been disposed of in a 2 legal manner. That wa s very helpful to the school 3 distri ct
. 4 other activities that I can think of that were 

### S h elpful that veolia provided to the school district 6 i n cluded at least four or five times a year at the 7 elementary level, mid dle -school level and high-school 8 level we asked for career-education speakers to speak to 9 our studenu about future oppOrtunities in the business 10 world

. veolia was always very cooperative about sending 11 speakers out. 12 It won't be a s urprise to you al l of our 13 extracurricular activities-

- we're constantly asking the 14 area businesses for don ations to support our activitie s . 15 veolia was one of the most generous sponso r s of all those 16 activities, and I can think of a - - t can r emember one 17 Christmas when they

. donated hundreds of pairs of gloves 18 and stocking caps to our needy families and, once again, 19 a good educationa l partner. 20 Perhaps, the IIIOSt important contribution ca. 110 in the 2l form of the Archview Economic Development corporation Page 23

V E S 004 762070908a 22 that Mayor s · auget talked about previously. During my 23 first year in the office, myself and Mr. sauget talked 

### 24 about what can we d o to promote economic development and 2S educ ation within the cahokia school boundaries , and t he 0 27

1 idea

-- well , the fi rst step was to invite several of the 2 business leaders of the communitY, and Mr . Harris was 3 quick to respond and accept that invi tation. 4 I know Mayor Reed was there as well. I think other S

### ~yors were included

. I think the mayor of cahokia at 6 the time w as there, and t he mayor of oupo also came, but 7 from that meeting w e started the idea of Archview 8 Economic oevelopment wi th the Mutual goals of promoting 9 e du cation and bus i nesses withtn the cahokia school 10 boundaries, and that was four or five years ago, and 1 11 know that it's been extremely effectiv e to date and

-- 12 MS. POPE: conclude. 13

### ~. DEETS:

-- one of the things, as a schoOl 14 superintendent, that we ask businesses to do, was t o 15 provide educational opportunity

. for high-school graduates 16 because high-school graduates ne ed to know that there's 

### a 17 connection from their schoo ling to work

. And every year 18 M r. Harris would call the high school and say, we have 19 opportunities for these two to five jobs; w ill you send 20 us some of your best high-school graduates so that we can 21 employ

### the~ in our area, and I can tell you during my 22 tenure at cahokia t hat veol i a was one of the most 23 valuable bus i ness partners,

### c~nity members we have , 24 and because of all t heir support for the school distri ct , 25 I'm here to speak on behalf of their Title v Air Penait. Page 24

VES 0047630

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 

## zo 21 22 23 24 25 0 070908a
28

Thank you.**•~·** POPE: Next is Brad ). Harriman.**~1R .**  HARRIMAN: Present. GoOd afternoon. MY name is Brad Harrilllan. I'm the Regional superintendent of schools for st. c lair county. And I don't want to be redundant in soae of the things that Jed touched upon. I'll tel l you a little bit about .,yself first. I've been a life-long resident of St. clair county. I've been in education in this county for t hirty years. S tar t i ng my thirtieth ye ar now . I've served as a teacher, a coach, adMinistrator in both private and public sc h ools

. I've served the last two years as regional s up erintendent. I was e l e ct ed to the position in November of 'o6

. Mine is an elected p osi t ion that really seeks to serve all of the c i tizens and the school di stricts of st. c la i r cou n ty. our office is, bas i cally, a compliance ar• of the State Board of Education

. Not every schoo l district

- - there's over nine hundred i n the state of Illinois. Not every school d istrict can contact the State Board of Educat io n directly so they seek servi ces t hrough the regional office. Anything from com pl iance of school po lic ies and sc h ool codes to laws governing attendance, discipline, thi ng s like that. I've only come to know Doug Harris in the last two

Page 25 29

VE S 004 7 640 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 070908a years since I •ook •he position as regional superintendent. He introduced hims el f

- - actually, it was Jed that introduced Doug and I, and Doug right away wanted to offer his services personally and any services that his company could offer the school districts of st. clair county. so 1 didn ' t really know what veolia did at the time, but Doug informed me of not only what they do but who they employ so I'm here more to speak about

-- about the character. 1 don ' t know much on the industry side of this thing, but I can say that ooug Harris has never turned me down

. He's a friend to education i n st
. clair county
. I've had to make a call

-- I had to make a very difficult call to him. In my coaching days you get pretty close to a lot of young men and women, and I had a young man who had really fallen on hard times, and he was homeless. His marriage had fallen apart. His life had fallen apart
. He was really struggling and he needed

-- he needed somebody to help him get on the right track. so one of the phone calls that I made was to Mr. Harris about employment opportunity for the young man , and he ' s worked very well v nth me in trying to get this guy back
on the right track. 25 so when it comes to character, I have a lot of
30

1 respect, and I hold him in very high reg ard

. I have 2 toured the facility. AS I said, I don't know much about 3 the industry, but I've toured the faci li ty, and ooug has 4 informed me about the service that his company does Page 26

VES 004765D 5 6 7 8 9 10 

## u u l3 14 

### 15 16 17 18 19 20 21 22 23 24 

### 25 070908a provide

. I do know that his company is a vital part of s t
. Clair county. 1 feel t hat

### e~ployment at veo11a gives people an oppo r tunity to earn a decent liv i ng w age and become productive taxpayers, and I certainly appreciate that. so not only am I he re to speak for veolia and for Mr

. Harris, but I 'm also here to thank him . T hank you. MS. POPE: oid we have another speaker, &en? MS.**~reo:** Dee Reed is in attendanc e. MS. POPE: oee Reed. MS. REED: Thank you very much. MY name is oee R

eed, and I

### ~ here today to speak on beha l f of veolia f or the permit. I am s peaking today as a cahokia residen t. I'm a life-long residen t of cahokia. I was born in 1953 so you can do the math.

### ~ fifty-five year s old, but 1 come here because I am a

### for~er mayor of the vil l age of cahokia. I serv ed as the mayor

### fro~ 2001
tO 2003. Prior t o that, 1 worked at the cahokia public Library District for twenty-four years. so in rxry capaci ty as lib rary employee, I was also a school board Member for cahokia unit school District

. It was there 31

1 t h at 1 first heard about Trade w a ste I ncineration, and 2 some of you

### ~y or

### ~a**y** not know that veolia has h a d a 3 number of names over the years. AS Trade waste 4 Incineration, I just knew th at they were doi ng some 5 t hin gs w;th t he school, but it was only when I go t to the 6 Mayor's office, that t tru l y l earn ed about what onyx 7

### Env**ron~ental** then did when I was called upon by Mr. ooug 

### '

Page 27

VES 00 4766070908a 8 Harris to come and do a tour of the plant. 9 well, obviously, when you're a new mayor, everyone 10 calls on y ou to do tours of places

. Not. ooug was 11 probably the only one that kept pursuing m e and saying , I 12 really want you to come out here and see th e plant and 13 see exactly what we're doing here, and 1 did tour the 14 plant. 1 not only felt very comfortable that everything lS was being done to the lett er of the law, but I saw the 16 employees, and I became very

### f~iliar with a lot of the 17 emp1oyees. 18 I'm smiling at Gale olden right now. Gale not only 19 would call the office on nu merous occasions asking what 20 they could do for the village of cahokia, what could we 21 do f or the schools and for the village, itself, and they 22 were always there for any kind of K iwanis, any kind of 23 Rotary , any kind of tournament, any ki nd of event. 24 Always interested in halping children of cahokia and the 25 families of cahokia and I saw it over and over again. 0 32

1 I do want to say the main thing I wanted to say 2 today is in the

### ~~~Ayor's office you h ear a lot from people 3 from all levels

. You hear from corporat e leaders. You 4 hear from education leaders

. vou hear from normal 5 people. Normal people, you like that? 6 But what I want to say is you hear a lot of things; 7 that in living in cahokia near sauget w her e there's a 8 tremendous amount of i ndustry, you hear a lot about 9 green --and I don't ..ean green issues. NOW, today I 10 mean little green peop l e, l ike what happened way back 11 years ago, and I'm going to be rea l honest. I lived on Page 28

VES 0047670 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Edwards street. they**di~ d**  young. 070908a I played in oead creek

. MY parent s,

They d i ed at fifty-two and fift y-seven . why they died, you know ,

### ~edical is sues . I don't know that we can blame any one t hing, but back t hen I want to say that peop le did th ings that, perhaps, yo u wou l dn't
even think abou t doing today. Tod ay our IEPA , our different**govern ~ental**  regulations, we just

-- we are living in such a good worl d right now because we have people like ooug Karris and Gal e olden and George smith and all the p eople that work at veolia. 1 stil l live in cahokia. I want to live in cahokia, but 

### r want you to r e member on e thing that ooug Harris

- - he p ro bably won't even

### reme~ber he told me this. But when we did t hat tour of t he plant , he s ai d to 33

1 me, you know, we our based here in sauget , Illinois. but 2 there are only twO hundred residents that live in sauget. 3 we truly think of cahokia as our conmuni t y, and I want to 4 do anything we can to help the vi ll age of cahokia. 5 That's the k i nd of person oo u g Harri s is

. That' s the 6 kind o f leader ship that he l eads veolia Enviro nmental 7 w ith, and I speak out very s trongly for veolia. I s pe ak 8 out very strongly for ooug Harris, and I appreciate the 9 opportunity to address this group today. Thank you . 10 MS. POPE: A re t here any other speakers signe d 11 up a t this point? NO one? J ust

### ~s a reminder

- - just as l2 a

### r~inder**,** the deadl i ne f or all written comments are due 13 J uly 1 8t h

. The deadl i ne for all written cOMfients

. If 14 you have written comments, they're due by July 18th. Pag e 29

VES 004768ll 07090 8a 

### 15 okay. v ou can also go on l ine**~d** submi t comment s, 16 a n

d we have that web a ddress on the back of the agenda. 1 7 So you 111ay go on line and s ubmit c()fMients·, and , ag ai n, 18 the deadline

. is July 18th. xs there anyone who wou ld 19 li ke to give comments at this time? At t his time then 20 we' l l be gin our que stion-and-answer period. I' ll h ave 21 Genevieve and c harles Hall to come up front.
22 23 24 25 (whereupon, a recess was taken.)

·MS. POPE: At this time our publi c hearing will
34

1 continue. speaker Robert J. Mc co rmick can come on up.

### ~~**.** MCCORMICK: Thank you very much. Again, my 2 3 nrune is Rob McCor111ick

. 1

### ~ the found er and president of 4 Frank lin Engineering Group. Franklin Engineering is a 5 professional services cOIIPany located in the N ashville, 6 T ennessee, area that specializes in applications 7 involving h azardous-waste conbus tion and air-pollution 8 controls associated with that

. 9 1 and my colleag u e, Dennis K n

isley, are h ere today 10 to speak about t h e particular project that we performed 11 for veolia tha t we think has relevance to this 12 proceedi ng. This project invo lved

### ~~~an health risk 13 assess11ent for the faci1 ity.**1~** oennis is going to ge t into details of that. I'd 15 like to start by jun giving a bit of inuoductory 16

### infor~~~ation on our company, the tYPe of service we 17 perform and a linle background information on the risk18

### assess~**nt** process for those of you who may not be Page 30

VES 0 04769070908a 19 fami li ar with it. 20 FirS't of all, 111Yself, I'lll a chemical eng ineer. &y 21 way of education, I have a bachelor of science degree 22 f rom washington universitY here in st. Louis. Received 23 that in 1977. so I have thirty years experience. Almost 24 all of it is related to hazardous waste coMbustion and 25 air-pollution control of those types of sources. 0 35

1 MY experience includes desig n incinerator s , 2 operation of incinerators. I once worked for a cOMpany 3 si mi lar 'to, or in 'the same business. as veol ia

. I also 4 have some experien ce in environmental permitting and 5 perfornance 'testing of the se types of faciliti es. My 6 company, Franklin Engineering, specializes i n the

### sa~e 7 areas. In the last ten years, we've worked for about 8 forty incineration facilities nationwide that hold 9 boilers or other type of industrial furnaces that burn 10 h azardous waste. 11 MOst of these are chemical manufacturers are 12 disposing of a product t h at 'they or w as'te 'they generated 13

. i n hous e . so111e of them are us Government facilitie s for 14 e x plosive waste. some o f them are commercial 15 i nc inerati on facilities such as veoli a. 16 our services range fr om design and construction, 17

## modifica~ion of inc i neration facilities to preparation of 18 environmental-permit documents, performance-test plans 19 and a 1so risk assessments. And t hat's what I'm here 20 specifically t o talk about today. 21 For those of you wno are not familiar w ith risk Page 31

VES 004770070908a 2

2 assessme nts , it i s one of two ways in which the emissions 23 per form ance of hazardous-wa ste incinerators is assessed 24 and regulated. F i rst way that these

### e~issions ar e 25 regul ated i s through emission standards, which are 0 36

1 generally concentration b ased or percent removal based. 2 HaZardous-waste incinerator emissions were first 3 regulated in thi s fashion about-- well, in the early 4 1980s through the R esource cons ervation Recovery Act or 5 RCRA , as we r efer to it in the industry. These

### e~i**ssio ns**  6 are now regulated und er the clean Air Act MACT standards , 7 which are also co n centration-based standards

. That 8 acronym MACT stand s for maximum achievable control 9 technology. 10 A s 1 sai d before, t hese are co ncen trati on - based 11 emissi on standards. The particular pollutants that are 12 regulated

### ar~< diox i n and furans, total hydrocarbons, 13 carbo n wono x ide, particulate matter, HCL and chlorine gas 14 and variou s "' etals including mercury . There is also a 15 percent remova l base standard for What are called 16 ·principal hazardous organic constituents in waste fed. 17 compliance with all these emission standards must be 18 demonstr ated through perform ance tes ti ng under what we 19 called · worst-case conditions

. Tha• is

## mi**nimu~** combustion 20 t emperature ,

### MaX**iM~** waste

- feed rates, maxi m um 21

### •eta1s**a~d-chlorine** feed rates, maximum gas- flow rates, 22 et cetera
. 23 For example, t he current MACT standard for 24 particu late matter emissions is

. 0 15 grains per dry 25 standard cubic foot.

### I~ order to pass th e performance Page 32

VES 0047710

1 2 3 4 5 6 7 8 9 10 

### u 12 13 14 lS 16 17 18 19 20 21 22 23 24 25 0 070908a
37

test, the incinerator must be able to demonstrate particulate conce n trations in the stack gas less than the standard under worst-case operating conditions. All hazardous-waste incinerators, including veolia, are required to meet these**~CT** standards. In addition to the concentration-based standards, some incinerators have been asked to perform human health risk assessments under the auspices of the RCRA omnibus authority. This human risk assessment is a complex pr·ocess t hat i nvolves characterization of stack emissions, airdi spersion modeling, behavior of deposited pollutants in soil and water, and estimated uptake of constituents by animal and plant l ife. The ultimate goal is to estimate potential exposure by human beings through a variety of pathways i ncluding direct i nhalation and ingestion. we 've been involved in a**nu~ber** of these projec t s . At this point I'm going to turn it over to Dennis Knis l ey to talk about the details of the project we performed fo r veolia

. T hank you very much for your attention. MS. POPE: This \$ oennis R. Knisley. MR

. KNISLEY : Good af ternoon
. I ' m a registered prof essional engineer in the State of Tennessee, and 1 currently serve as vice President of Operations for t he Franklin Engineering Group , Incorporated

. 1 have a
38 Page 33

VES 0047720 l 2 3 4 5 6 7 8 9 10 11 1 2 13 14 15 16 17 1 8 19 20 21 22 070908a Master's of

### s~**ience** degree in

### h~**ic al**  engi neering and have spent th e l ast twenty-three years i n various positions related t o chemical process and application of environment r egulations nnd industrial**sour~es.** us EPA Region 5 performed a Risk sc reen i ng t h at included a number of simplifying

### ass~~pt**ons** for the veo li a incineration facility dated March 22, 2004. aased on the res ults of the ris k scre eni ng, us EPA

### e~omMended annual eaission limits for mercury, cadm ium and chronium that resulted in certain short-terll emission limits that were more stringent than the HWC MACT standards. T

he HWC MACT standard s fo r the other 11etals were determined protective of human health and environment based on those results

. In April 2004, Franklin E

ngi neering undertook the project to conduct a more detai l ed site spec i fic risk assessment in accordance with the gu idel i nes publi s hed in the 1 998 HHRAP Guidan ce

### oocu~ent for Hazardous waste combustion Faci li ties. This was a peer-re view draft

. That w as the prevalent ris k assessment methodology in us e at

### the**i~e.** R i sk assessment report was submitud in september 2004. The document was revi ewed by t he us EPA Region 5 an d Illinois**~3** EPA. A revised risk

### assess~ent report was submitted in october of the next year, 200 5

. T he f i nal HHRAP gu i dance 24 25 39

l document was also issued by us EPA i n september of 2005, 2 and several of t he clarifying procedures in that document 3 w ere u sed to prepare the october 2005 report. 4 Additionally,

### ther~ were a number of site-specific**~age** 34

V E S 0047730 5 6 7 8 9 10 ll 

## u 13 14 15 16 17 18 19 20 21 22 23 24 25 070908a clarifications and mo d ific atio ns relate d to airdis p ersing modeling, risk modeling and other iteNs that were u tilized to construct the october 2005 r eport
. The re s u lt of the risk assessment , whi ch is wh er e I'l l spend the re st of my tiMe talking are expressed in inc remen tal carcinogenic and no ncarc inog eni c effects frOM incinerator emissions on individuals t hat live within the ri sk-assessaent a rea. The risk-assessment protocol accounts for inhalat i on pathways, as well as other pathways , including the potential foo d-cha i n routes of exposure . The benchmark for evaluat ing the carcinogeni c effec ts reco m

mended by us EPA is t he individual risk associate d with exposure to potent i al carcinogens released from a single fa c ili ty shou l d not exceed l in 100,000. conduct of the veolia ris k assessment for carcinog eni c effects included evaluation of adult and chil d resid ent pathways, as well as adult and child re creat ional fish er pathways. All four of these scenarios res ulud in increment al
cancer ri sk less than the be

. n

chmar k of 1 in 100,000. Add i ti onally, there's a benchmark for ev aluati ng the 40

l non-carcinog enic h eal th effects, and those are a hazard 2 q uotient of 1.0

.

### ~ever, for t h e pu rposes of eval uating 3 non- carcinogen ic health effects from a single 4 i nciner ation facility, us EPA sugge sted th at the 5 calculated hazard quo t ient shoul d be less then 0.25, 6 which is four ti.es lower

. consistent with the 7 evaluation of the

### carcinog~nic risk , the no n-carcinogenic Page 35

VES 004774070908a 8 risk was re-evaluated in four distinct pathways, adult 9 and child resident and adult and chi ld recreation al 10 fi sher. 11 segregated h azard indices based on the target organs 12 were dev e l oped to evaluate t he non-carcinogenic effects. 13 The results presented in the october 2005 Ri sk · Assessment 14 Report indicate that f or eac h combination of consti tu ent 15 and pathway evaluated the hazard quo tient was less than 16 the benchmark of 0.25. Therefore, enissions evaluated 17 are not likely to impose adverse effects related to 18 non-carcinogenic hazard

. 19 To summariz e the discus sion of potential health 2

0 effects associated with emissions from the veolia 21 facility, based on t he conservative evaluation des cribed 22 in the october 2005 Risk Assessment Report, the potential 23 health effects, both carc i n ogenic and non-carcinogenic, 24 are b elow the benchmarks established by us E PA. 25 Therefore , the H WC MACT standards proposed in the 0 41

1 T i t le v permit should be protective of human health and 2 environment. Let me co n clu de with a practical 3

### c~parison. I drove from Nashvill e, Tennessee, tod ay to 4 addr es s th is me eting

. Ba sed on information from the 5 National Traffic

- . - N ational Highway Traffic safety 6 Assoc iat ion, in 2006 , there was an 860 i n 100,000 chan ce 7 o f bein g injured in a car accident. our risk

- assessroent 8 results indicat e that there is les s than a 1 in 100,000 9 chance that after thirtY years there will b e any 10 ca rcinogenic effects based on the conservative estimate 11 of emissions from the veoHa facility

. Thank you for Page 36

VES 00477 5070908a 12 your**a~tention.** 13 MS

. POPE: Is Karen vonley here?**co~** on, Miss 14 vonley

. To remind you, there is no drinking or eating i n 15 ' this room. 16 MS. YOHLEY: Good afternoon. MY name is Karen 17 vonley, v-o-N-L-E-Y. I'M a chemical engineer and a 18 licensed profession al engineer, and I was asked to speak 19 by veolia this afternoon on behalf of the veolia's risk 20 assessment , as spoken by the last couple of speakers. 21 I'm a principal engineer with Schreiber, vonley and 22 ASsociates in west county in st
. Louis

. we're an 23 environmental engineering firm, and as part of

### ~y 24 respons ib ilities with our Hrm, I've been involve d for 25 over the last twenty years with hazardous wa ste 0 42

1 combustion facil i ties, with the

### pe~itting and study of 2 the eaissions of those facilities. 3 so my experience has i ncluded, for example, applying 4 the clean Air Act regulations and the Resource 5 conservation

### ~ecovery Act regulations, worki ng on permit 6 applications and permit conditions for the hazardous 7 was te-combu stion facilities, analyz i ng emissions, testi ng 8 results and coordinating and studying the results of 9

### ~ulti-pathway risk assessment that, again, that Franklin 10 Engineering speake rs were talking about. A nd that is 11 used as a component of the permitting process . 12 I've been involved with risk-assessment topics for 13 hazardous-waste coobustion facilities in EPA's Regions 4, 14 5, 6 and 7, and those include faciliti

. es in the states Page 37

VES 004776070908a 15 of: Arkansas. Missouri. Kansas, Indiana, Tenne ssee, 16

### ~i**ssissippi,** south ca rolina and Texas. so I have been 17 involved w ith a lot of what's been going on in the united 18 States to see the kind of examples of the studies that 19 have been done. 20 so due to my experience in this area, I was asked by 21 veolia to provi de a peer review of the approach and the 22 result of the risk

### assess~nt that was prepared for the 23 veo l ia incinerators by Franklin Engineering. My

### c~nts 24 are based on both our company's involvement in the Title 25 v permitting process that Bob Schreiber spoke about and 

### a 43

1 t h at is the subject of this meeting and our rev iew of the 2 risk assessment and the resul t. 3 A little bi t of a repeat, but I wanted to speak a 4 moment again about the pu rpose of the risk assessment and 5 the permitting process. As also said, the incinerati ng 6

### en~issions are regulated in the Title v by the hazardous

7 waste combustion, which is KWC, MACT regulations and $ those specified emissions

### i~its fo r dioxin,

### ~tals**,** 9 carbon

### ~noxide, THC and HCL/c2, and those standards were 10 established by EPA over Many years through evaluating the 11

### aximu**-achiev able**  controls of these types of facilities 12 and then also verifying that these t:ypes of

### e~ni**ssions** 13 were protective through a**risk-assess~nt** process on a 14 national basis. 15 once the standard s were established, they were 16 applied to all the hazardous-waste combust i on faci l ities 17 such as veolia. The Resource conservation Recovery Act 18 or RCRA permitting process is where the risk assessMent Page 38

VES 0047770709Q8a 19 results are actually reviewed and applied. That ' s a 20 separate and additional permitting process from the Title 21 IV, and the RCRA permitti ng process includes

### t~e 22 requirement for EPA to address protectiveness of t he 23 human health and the health of the environment on the 24 site-specific bas is for each permit

. 25 so the risk-assessment tool can be used and is used 0 44

1 to document the facility e111iss i ons are protected both on 2 a short and long-term basis. veolia has prepared a risk 3 assessment, as de scribe d by Frankl in Engineering, to 4 document that the MACT emissions standards that are in 5 the Title v

### ~re pro tecte d. Therefore, although it ' s part 6 of a separate permitting process, the result can al so 7 provide soroe assurance to the clean Air Ac

. t permitting 8 process. 9 FroM NY review. 1 found that the app roach that's 10 used in the r i sk assessment for veolia is based on EPA's 11 guidance and 111ethods that are currently being used across 12 the industry for perm in1ng

. The EPA 11ethods, as alr · eady 13 i ndicated, are based on very cQRVlex methods and 14 guidance. The process allows for a combination of both 15 site specific and default assumptions for the modeling 16 paramete rs. 17 I found that the veo1ia r1sk assessment follows the 18 guidance and MOdeling approaches as used across the 19 nation and different infornation also that's available by 20 EPA for r is k assessment, and it does both the default and 21 site-specif i c assumpti ons. Page 39

VES 004778070908a 22 As typical, many worst-case assumptions are used in 23 the r i sk assessment , and, for example, i n this one, one, 2

4 that the use of h ighes t -maximuM emissions is used, as 25 apposed to the actual eMissions that are seen over the
45

1 course of the thirty

- year period that it studied. 2 Also, the point of maximum impact that's determined 3 from the air-dispersion modeling is us ed ins tead of. where 4 people would, actually, reside and have activity. so 5 both of those would act to significantly overstate any 6 potent i al maximum e m

iss i on impact

. 7 T herefore , that ' s -- a l l t hese conservative 8 assumptions are w hat helped render the risk assessments 9 to be conservative in nature. In veolia ' s case vmere the 10 site-specific assumptions have been used, the faciliW 11 gathered data to docu m ent the appropriateness and 12 representative of the information. 13 The result of the risk-assessment study that I have 14 reviewed for Veolia document that any potential cancer or 15 non -cancer risk to human health from facility emissions 16 i s lower than the acceptable threshold established by EPA 17 as was also mentioned by Frankl i n . The hazard quotient 18 for non-cancer effect and t hen any carcinogenic effects 19 is one in a hundred thousand, and the facility is below 20 those benchmarks. 21 Therefore, in conclus i on and based on my knowledge 22 of the veolia i ncineration facility and hazardous-waste 23 combustion permitting, I believe that veo l ia's risk 24 assessment is both representative of the approaches used 25 across the industry, and that the MACT emission l imits Page 40

VES 0047790

1 2 3 4 5 6 7 8 9 10 11 

## u 13 14 15 16 17 18 19 20 21 · 22 23 24 25 0 070908a
46
that are in the Title IV**pe ~m** **it** are expected to be protective of human health. Thank you. MS

. POPE: Leah oettmers
. What 's the name of the first speaker? MS. OAI'UCO : State Representative Reitz

.**~~** POPE: state Representative Reitz.**~~.** REITZ: I'm state Representative oan Reitz. I serVe as state representative for the ll6th District, which includes sauget and veolia technical solut i a plant. I'd like to start by thanking the US EPA and thank you for the hearing and working with the Illinois EPA on the regulators to assure that the company operates good and proper permits to safely op erate in m y district

. The veolia plant and similar comp. anies I think play an impOrtant ro l e in cleaning up our environment and providing a safe place for disposal of hazardous waste. I've had several opportunities to visit the facility. I'm extremely impressed by how professional and conscientious the workers are when I've been on the tour. I' m also aware of the outreach program this p lant has with the community, and they work with the local high school and posting career days , and they have been a good employer and put ting some of the youth to work as they graduate from high school

. . They've also established a great working relationship with the emergency planning
47
Page 41

VES 00 47800 1 2 3 4 5 6 7 8 9 10 

### u 12 13 14 15 16 17 18 19 20 21 

## n 2 3 24 25 070908a**c~ittee** and the village of sa uget. veolia is an integral part of th e economy in sauget an

d in my district and provides over two hundred jobs through the region

. we app;eciate the inves t ment they make and the valuable service they provide

. There's a need t hroughout our country to expand these types of facilities. To meet the**de~ands,** more produ cts are classified as hazardous waste. Hazardous waste in an effort to provide a s afer and cleaner environment for our citi zens. s peaking with local el ected o fficials,

### I'~ aware of the ho pe that future expansion for the veol ia cOftpany wil l be in the sauget area. This potential expansion would be wel come by our r egio n, and I would offer my assistance in any project t hat provides any type of
e conomic developQCnt
. I'd like to thank you, on ce again, for your work and the EPA to guarantee that we have a safe p lace to dispose of hazardous waste, and that we have adequate protection fro• the danger s that**i~roper** disposal would have on our
area. Thank you. MS. POPE: Leah? MS. DAMICO: L eah is still not in attendance, but Darryl elbe is here. MS. POPE: Darryl Elbe

. oarryl E lb e, wou ld 48

1 you, please, state your full name, and spell your last 2 

### nare. 3 MR. ELSE: My**n~e** is Dar r yl Elbe , E-L-8-E. I 4 am retired Emergency

### Manage~ent Agency Director for S t. Page 42

VE S 0047 8 1070908a 5 clair county. Retired in 2006

. . served about 6 sixteen years and I just wanted to say this about 7 well, Trade waste and then onyx and now veolia. That in 8 my years of being emergency Management Director, we never 9 once had to respond to a sp ill or a release down there. 10 They've been very good. They ' ve been good to work l1 with

### ~nile 1 was there. They're still good to work with. 12 They've

-- we've had the opportunity to form a haz.at 13 team, hazardous -aterial t eam, in St. clair county. They 14 were a very intricate part. 15 A gentleman by the name of steve

### ~uthy (phoneti c) 16 provided us space to hold our meetings with all the 17 people when we first formed the hazmat teaM. T hey were 18 great to work w ith and I' m sure as a member-- I still 19 serve on the st. clair special Emergency services on 20 their board, which is the hazmat te aOI here in St. Clair 21 county, and I look forward to working with the people 22 fran veolia, and 1 thank you for your**ti~e.** 23 MR. FEHER: GOOd afternoon. MY naJ!Ie is oon 24 Feher, retired fire chief from Fairview Fire oepart..ent, 25 Fairview Heights, Illinois. I was county fire chief, 0 49

1 association president for a period of so01ething over 2 fifteen years. After fi fteen 1 stopped counting. Also, 3 the LEPC chair for the county, local emergency planning 4 committee chairman for st. clair county and that was well 5 over fifteen years. 6 I was appointed to that position by then county 7 Board chairman, John 8aricevic, and carried on since th en Page 43

VES 004782070908a 8 under th e current. Mr. Elbe pretty much took some of the 9 thunder away

### fro~ what I was going to s ay in that we had 10 a very active , and we do have a very active, LEPC 11 committee. 12 The need for response capabilitY because we don't 13 see a l ot of incidents within the site or

### co~ino from the 14 industries that are

### h~ based here in the county as much 15 as we do by rail and by truck, and it' s the ability to 16 have a response capab1lity throughout the county was very 17 i ._,ortant
. 18 And the indu stries soae ten years ago worked with us 19 very closely to help establish that organization. veolia 20 was very much a part of that. I t wasn't called that at 2 1 the t ime

. It was onyx, and we had Mentioned Steve Luthy, 22 and steve played a very notable part in that

. we used 23 t he ir facility fo r probably about a six-month period with 2

4 attorneys out of spri ngfie ld, from the Attorney General's 25 office, Illinois EPA, State's AUorney here in St. clair 0 

## so

1 county and a couple of attorneys, and als o the attorneys 2 from various industrie s helped structure an organiz ation 3 used in response. 4 veolia, we used their facil ity

. Ran up their pho n e 5 bills and all that sort of stuff, and even today the 6 organizati on exists primarily through donations and 7 stuff, and they did play an integral part. 8 As LEPC chair, t monitored the industries, who have 9 had hazardous**~terials** and stuff within the county , are 10 required by law, by federal statute to report to us, and 11 I monitor that reporting. They've been faithful about page 44

VES 0 0478307090 8a 12 their reporting to u s and " · hat they do have so t hat we 13 can share that with the fire depart ments and especially 1.4 the hazmat team, which serves the enti re county. 15 They ' ve done an excellent job

. I'v e worked with 16 Mr

. Lu thy very closely during the formation and got to 17 understand their fa cets of things and especially t h e 18 safet y. Took me through some of t he ir safety plans 19 through their faci lity a nurr.ber of times to show s0111e of 

### 20 t he safeguards and s t uff in t heir facility. Look forward 21 to ••orking w i th them even more and, I guess , that's about 22 all I've got to say at this point i n time. Thank you. 23 MS

. POPE: Are there any more s p eakers? IS 24 there anyone that would like to**ke** p ublic comments? Is 25 there anyone who has a ques t io n that th e y need an swered? 0 51

1 coul d you c 011e to the podi um , please? This is carrie 2 vo n ley? 3 MS.**O~ERS:** NO, I'll Leah Oettmers. I do 4 apologize for m y tardiness

. upon review of the permit 5 applications subotitted by veo11a, 1 have determined that 6 this project is consistent with the F i nal P r eferred sol id 7 waste Management Plan fo r Madison county. 8 Veolia's operation of th e ir incinerato r and 9 recl amation department has be en beneficial to Madison 10 county and its residents by di sposing of waste suc h as, 11 unused medi cal wa s te , l atex/o i l based paints, and other 12 household hazardous

### ~at**als. Wi~hou** **t** the much-needed 13 incinera t or , only o ne o f three in the country, residents 14 and departments of Madi son co u nty would

### inevi~**ab y**  be Page 45

VES 0 04784070908a 15 storing tons of waste in their homes and warehouses, 16 possibly in violation of federal, state and local solid17 waste or dinances. 18 I n october of 2007, veolia provided their serv ices 19 and incinerators to dispose of 300 pounds of unused 20 medical waste from 2,000 homes in Madison county pro 21 bono. They have disposed of waste proper l y in 22 partnership with the folloorlng organizations: Madison 23 County sheriff, Southern IllinoiS Law Enfo rcement 24 commission, SlU -E school of Pharmacy, 1o1adison county 25 Board office, Madison county Recycling, Madison County 0 52

1 P lanni ng and Developme nt , and other numerous municipal 2 departments or law enforceMent

. 3 Since 2002, veolia has also partnered with IEPA and 4 Madison county Recycling to fuel blend/recla i m latex and 

### 5 oil-based pa i nts frOM the public, averaging almost 20,000 6 gallons a year. 

### 7 In conclusion, the operations of veoli a are secure, 8 eff i cient, and well

- maintained. All aspects of safety 9 are top priority for emP,loyees, as well as the 10 surrounding areas and envi ronment. As solid waste ll coordinator fo r Madison county , it is my professional 12 opinion that veolia would be considered for the permit 13 for the benefit of Madison County and its residents. 14 Thank you. 15 MS. POPE: Anyone e 1 se have a cOII'IIIent at this 16

### ti~? would you, please, state your

### n~e. and spell your 17 last name . 18 MS.

### LOGAN-S~ITH:**I'~** Kathleen Logan-Smith. Page 46

V E S 0047 85070908a 19 I'M the executi ve director o f the Missouri coalition For 20 Environment. we inhale across the r iver and breathe the 21 air occasiona l ly from your side. And I just wanted to 22 encourage the EPA to peny this perMit today

. This 23 facility's history do es not suggest that it-- i t needs 24 to remain in operation, as it has been operating

. 25 The

-- whi le whatever is in the analysis, the risk 0 S3

1 analysis and whatever is in the permits might be 2 protective, what's genuinely protective or not protective 3 is how it actually operates on the ground and what' s 4 coming out of the stack, what 's actual l y in the air that S we breathe

. 6 And one of the things that also we need to think 7 aPout is this facility is not alo ne . There are a nu mber 8 · of facilities in the area ttiat are adding to the burden 9 that we breathe, and so cumul ative i m pact i s something 10 that needs to be considered in conmuniti es that are low 11 i ncome and minori t y communities that have already more l2 than their share of environmental hazards that they have 13 to deal with

. 14 Particulate M atter out of the facility is of 15 particular concern for t hose of us in the non-attainment 16 area looking for, you k n

ow, ever more research that comes 17 out that shows fine particulate matters leads to heart 18 di se . ase and a . number of health p rob1 ems and causes 19 numerous deaths across the region. 20 The ot her item of concern in our region and to me 21 p ersonal l y is lead because there is no safe level of Page 47

V ES 004786070908a 22 exposure

### ~o lead, and l ead is on e of t he items that is 23 emitted from the f acility. so the

- - 11hen you look at 24 what comes out of t he facility and what is added to i n 25 the region, we need to be cautious and careful about
54

1 whether a faci l ity that has an operating history l ike 2 this one does deserves another permit, and then if we 3 decide to permit such a facility, we need to make sure 4 that it has the compliance schedul es in it to maintain 

### S compliance and the**~nitoring** in it to al low us to make 6 sure it's happening the way that it should and the 7 enforcement from IEPA that makes sur e that it actually 8 delivers on t he pro m ises that are made in that permit 9 because it's not the equations that are going to protect 1 0 your children, and it's not the fonuulas and the modeling 11 that are going to protect us. It's what ' s, actually, 12 coming out of the stacks at any giv en moment. It's hol1 1 3 well things are handl ed there and whether people are 14 whether the operation is

-- is ex ceeding minimum 15 standards. so we'll submit more detailed comments by 16 wri tin g . 17 MS. POPE: Any more publ ic comments? Do we 18 have any questions that we can answer at this time? 19 20 21 22 23 MS

. ANDRIA: Come on up, Kathy. (Whereupon, a recess was taken

. )
MS. POPE: Again, remember the deadline for 24 written comments are July 18th. At this time w e 'll be 25 taking

- - maybe we're going to take just a couple Page 48

V ES 0047 870

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 2l 22 23 24 25 0 070908a

minutes, just a break, maybe five, just to get some water. Thank you for coming, and we ' ll start again at ten after. (Whereupon, a recess was taken .) 55

MS. POPE: we will now reconvene. we will now reconvene fo r our five o'clock pub l ic; hearing. Good evening, everybody. MY name is Janet P ope, and I am a**co~unity** Invol vement coordinator with the 

### us Environmental Protection Agency

. Tonight I w ill serve as your hearing offi cer. we have**~vo** other peopl e from the 

### us environnental Protection Agency with me. 

### we have Genevieve Damico, who is an Environmental Enginee r, and charlie Hall ,**~~o** is also an Envi ronmental engineer w i th the US EPA. Tonight we are to share infonoation, listen to your questions and cOdments concerning EPA's proposal of a draft-operating permit for veo lia Environmental services located in sauget, Illinois. I hope when you**cat~~e** i n, you signed in

. what that does is puts you on our mailin g list, and i f there's any i n fo rmation coming up regarding the site, we'll IIAil that t o you. Tonight's hearing vrlll be three parts. First,
56 Page 49

VES 0047880 1 2 3 4 5 6 7 8 9 1 0 ll 12 13 14 15 16 17 18 19 20 21 22 23 24 25 070908a Gene vieve Dam ico wil l provide an overview of th e draft permi · t. second, we will take your coments f or the record; and, third, if time allows, w e will have an informal question-and-answer period

. Now, with the exception of the informal question-and -answe r s e ss i on, a cou rt reporter to my right w

i ll be •aking a transcript of th e entire period with th e exception ' of the question -and-answer sess ion, a . n

d that transcript will be on fil e in our administrati ve record. v

ou can also call Genevieve if you w ant a copy of this

. All persons w i s hing to spea k tonight, when you s ig ned in, I hope you checked the 

### oo You Plan to Make**c~ments,** there i s a ye s box, and now Genevieve oamico will gi ve an overvi ew of the draft pe nnit

. MS

. DAMICO: Good evening; t he veo li a E

nv i roruoen tal T echnical services from sauget, Illi no i s, is a treatment , storage and disposal facility, whi ch accepts offsite waste for further di spos al through in

cineration. containers and bulk shipments of hazardous and solid wastes are received, analyzed and transferred to tenpo rar y s t orage facilities, processed and incinerated in on e of three combus tion un its

. veo11a is located in an area that is attaining all of the national ambient**ai r~** **ua li** **ty** standards except for the eight

- hour ozone an d particulate matter less than 2

. 5

57

1 microgr&Ns standard

. 2 v eolia requires a T itle v pemi t because it is a 3 r.ajor source of hazardous air pol l utants subject t o 4 requi r.,..ents under section 112 of the cl ean Air Act for Page SO

VES 0047890 5 6 7 8 9 10 11 1 2 13 14 15 16 17 18 1 9 20 21 22 23 24 25 070908a boilers and hazardous-waste combustors. Title v of the Clean Air ACt requires, i n part, t hat all major sources subject to standar ds under section 112 operate in accordan ce with a permit

. MOst Titl e V ope rati ng permit s are issu ed by state or local permitt ing authorities

. EPA is iss uing this permi t bec ause in response to a pe ti tion from th e sierra club and the American B ortOlD conservancy, EPA obj ec ted to the per11h proposed to be issued by t he Il li nois EPA. unde r Ti t l e 

### v, when EPA objects to the proposed permit, the state operating

-- permitting au thority ha s the opportuni ty to address EPA ' S co n cerns, but if EPA's concerns are not addressed i n a timely fashion , then EPA becomes re spons i ble for is sui ng or denying the permit. In th i s ca s e , I l lino i s EPA did not respond to EPA' s concerns i n a timely manner, and on september 29th, 2006, EPA announced its int ent t o issue or deny veolia a federal Ti tle v penait. veolia submitted its permit applicat ion to EPA on May 2nd, 2007

. EPA deemed the appl icat ion admi nistrativ ely compl ete on June 13th, 2007

. P

ursu ant to a proposed**se~tlement agree~nt**  between
58

1 EPA a n d the sierra club and t he AMerican Bottom 

### 2 conservan cy, EPA intends to**co~~l te**  t h e publ ic comment 3 process by July 18th, 2 008, and i ssue or deny a fin31 4 per11i t by september 1.2th , 2 00 8. 5 concurrently wi th t his permit ting process, EPA has 6 alleged that veol i a is in nonconpl ianc e with th e clean 7 Air Act

. N othing in this permi t will shield veolia from P

age 51

V E S 00479 0070908a 8 any enforcement action related to past or ongoing 9 viol ations that we have alleged. 10 EPA has i ncluded a compl i ance schedule in the draft 11 permi t that requires veolia to test all three combustors, 12 to develop operating parameter li mits for emissions of 13 mercury, low-volatile netals and semi-volatile metals as 14 required by the hazardous waste combustion MACT. The 

### 15 draft permit requires t hat veoli a

### su~it the results of 16 tlti s testing and rev ised operating paraJneter limits by 17 september 26, 2008. 18 If EPA finds the revi sed operating parameter limits 19 acceptable, EPA w i ll reopen the permit to propose 20 incorporating the operating

### para~eter limits developed 21 from the required performance test into the final permit 22 and solicit publi c comments on the incorporation of the 23 operating parameter limi ts into the permit

. In addition, 

### 24 the permit may be reopened at a future time to 25 incorporate additi onal appl i cable requirements or 0 59

l compliance schedules. 2 MS. POPE: EPA public participation regul ations 3 require EPA to publish a publ ic notice in the local 4 newspaper. The public notice appeared in the East St. 5 Louis Monitor and the Belleville News oemocrat, both 6 published on June Sth. In addition, infora1ation was 7 mailed to those who attended I l linois EPA public hearing 8 for veolia and the heari ng for veolia's neighbor, 9 solutia. Now, we'll begin our publi c comment period. 10 I'll cal l th e speakers that have called and s i gned up 11 first, and then I 'l l call the speakers who have signed up Page 52

VES 0 047 91070908a 12 in the back after that. 13 when you come up , please, say your full name, and 14 spell your last name fo r our court reporter. If you have 15 written comments and you don't want to speak, would you, 16 please,**~ke** sure either myself, Gen evieve or charlie get 17 those comments before you l eave. 18 so that everyone who wishes to speak has a chance to 19 do so, please , limit your comments to five minutes. At 20 the fi ve- mi nute period I wi ll ask you to conclude

. You 21 will have an extra mi n u

te to concl u de withyour comments 22 at that**ti~ .**  If you don' t have enough time at that 23 time, you can either write and submit w ritten comments of 24 your remaining comments or either you can come back up 25 once the floor is clear . You can come back up and finish 0 60

1 your comments
. okay. Remember, when you come up to 2 repeat your name, spel l your last name for the court 3 repo rter, an d we'll begin this comment period at this 4 t ime. 5 The first person that I'm going to call is Herb 6 simmons. 7 1<\R

. SU I MONS: Good eve ni ng. My name is Herb 8 simmons, s-I

- M -M-0-N-S

. First of al l, I 'd · l ike to thank 9 the EPA for hol ding this hearing here, bringing the 10 inf orm ation to light to the publ ic. I've been the mayor 11 of East carondelet for the past twenty-four years , and I 12 have a good percentage of my residents have been emplo ye d 13 by Veolia, and over t h e last couple weeks I've had the 14 opportunity to talk with some of those employees and Page 53

VES 0047920 070908a 15 their families t o f ind out anything I could about the 16 company, either positive or ne gative, an d I h aven ' t been 17 able to fi nd any negatives. 18 The people that I've t alked to have assured me 19 it's a good company to work for. Ever ybody is h appy . 20 Everything for people who have been there f or 14 , 15 , 21 even as hi gh as 20 years that's been employed there

. I 22 also wear another hat. I've be en in t h e EMS busi ness for 23 38 years, and, to my k nowledge, in all these years and 2

4 t h e years that veo 1 i a. has been in operation, I have 

### no 25 knowl edge of a ny type of prob lems, any disa sters or 61

1 anythi ng taking place that we would have been respon ding 2 to
. 3 so I'm here just on behal f of the village of East 4 ca rond elet and the peopl e that veolia employs there, and 5 I would ask that the permit that they are applying for be 6**gi~ n**  great consideration

. There ' s too many people out 7 of work now . I don't need any other people i n my 8 community without a job

. Thank you very much. 9 10

. MS

. POPE : The next s peaker is s harece Johnson

. MS. ' JOHNSON: Good afternoon
. My name is 11 sharece Joh nson , J- O

- H-N-S-0-N. I am the corporate 12 Marketing communications Supervisor, f or Kenneth Hall 13 Regional Hos pi t al. A couple years back we held a 1 4 celeb ration in honor of National safety Month, which i s 15 in June , where we give a safety festival to the r esidents 16 of t he communit y. About 300 people came, and at that 17**ti e**  veolia was nice enough to be one of our corporate 18 citizens, and they sponso r ed the ev ent
. About 300 people Page 54

VES 004793070908a 19 came to the event. · we were able to raffle off over 30 20 bicycle helmets, a young girl bike, a young boy bike and 21 a teen bicycl e. we also had free food and free raffle 22 items fo r everyone who attended, and we are very, very 23 appreciative of veolia's support on that date. Thank 24 you . 25 MS

. POPE: Is Rhonda sauget? 0 62

1 MS

. SAUGET: Yes. T hank you very much and good 2 evening. My name is Rhonda Sauget, and I aM the
·. 3 executive Director of Archview Economic Development 4 Corporation. Archview**Eco~ic** Development Corporation 5 is a 511C3 organization created about seven years ago 6 with the mission of networking resources to help build a 7 strong fiber for the communities we serve. we represent 8 over 60 businesses, education and health care 9 organizations i n cahokia, centreville, Alorton, sauget, 10 oupo, East carondelet area . Archview's mis sion is to 11 provide a strong social, educational and bus in ess U i .nfrastructure for the underserved communities with some

· 13 of these cOfllllunities listing among the poorest 14 communities in the nation b y household income. 15 Doug Harris, plant manager of veolia, formerly onyx, 16 was a founding member and financial contributor to our 17 organization. Since it's creation, Doug Harri s currently 18 serves on our board, and veolia is a strong supporter of 19 the community activities that we sponsor. His commitment 20 has clearl y**de~onstrated** veolia and his tireless 21 dedicat io n to improving our communities and enhanci ng the Page 55

V E S 0047 94070908a 22 things that we do in the underserved areas. 23 veolia's corporate social responsibility goes far 24 beyond what ot her companies in our area have done over 25 the years . For examp l e, veol ia has parti cipated and 0 63
1 · cont ributed signi f icantly to many Archview activities, 2 including our career day. At our career day we have over 3 400 underserved students from oupo and cahokia school 4 districts , juniors and seniors that have come for the 5 pa st four years . Those students learn about why it's 6 important to stay in school, why it 's important to 7 graduat e and make gbod grades. career day also teaches 8 our students about job opportunities in the communities 9 so our kids can have the hope of staying in our community 10 and having a good, wonderful life with their family, and 11 certa i n l y the fut ure of our area can build on that. 12 veolia has also participated in the oupo centennial 13 100th Year celebration. This cel ebration helped the area 14 and the village of oupo really take pride in their 15 communi tY, and this is also one of our und e rserved areas . 16 As mentioned just a few m inutes ago, Veolia sponsored the 17 Kenneth Hall Regional safety oay event buying bicycles, 18 helmets and sponsori ng many· safety activities for the 19 children of east st
. Louis, and that was a very important 20 event, and it was wonderful for our kids

. 21 our communi ty needs the jobs that veolia brings to 22 our residents. 

### we need community support that veo l ia 23 brings to many of our organizational activities. In .24 short, we need and want veolia in ou" r community. we 25 applaud veolia f or its outstanding community support Page 56



## ves oo4 7950

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 0 070908a
64 throughout the years, and we strongly support veolia's US EPA**~rmit** application

. Thank you very much.**~15.** POPE : Are there any other speake r s signed up in the back , Charli e ? MR. HALL: No
. MS. POPE: Is there anybody that would like to give a publ ic comment at this ti•e7 Is there anybody who has a question that they need answered at this time? okay . Well, t h e deadline for written comments are July 18th. You can submit them in writing. You can submit them online, but everything is due by July 18t h. The public hearing we're still going. I ' m just talking, but I encourage everybody, who wants to**~ent,** to**co~ent,** whether i t is oral , in wri t ing , fax , on line, I encourage everybody to comment. AnY comments? Any**ques~ions?** sure, cOMe on up ,**Ka~hy .**  MS. ANORIA: I'll ask from here. (whereupon, 

### a recess was taken.)

MS. POPE: okay. we'll continue w ith our public hearing . And I'll just s t ate this; that if you have not signed up for a slot on th e public comment sheet, th i s is your l ast chance to do so. After we finish this pub l i c c omment period, w e wi ll not go back to
65 Page 57

VE S 00 4 7960 l 2 3 4 

## s 6 1 8 9 10 ll 

## u 13 14 15 16 17 18 19 20 21 22 23 24 25

l 070908a the public comment period. we will not go back

. we will do the public comMent period at this t ime. We will end with our question-and-answer section. w e w i ll not go back to the public comment period. so if you wish to**~ake** a publ ic comMent, please sign up at this time. IS Frank Bergman here? Our first speaker, Frank Bergman. MR. BERGMAN: I'll keep this brief and to the point, but 1'• glad I had the opportunity to come here today to address everyone t hat's here and speak about my relationship

-- our relationship t o the vil l age of cahok i a's relationship-- I'm t he mayor of the village of cahokia

-- with veolia and**for~ ly**  onyx . when I f i rst took over as mayor , I think what we asked for from all of our companies, bus in esses, corporations t hat work there is that th ey work with us, keep us informed, and veolia being just a little bit outs ide does cross into our community. so we have had a very good relati onship in that they make their bus in ess open to all of our other bus i nesses. We open it up so people can see what it is that they do. They coomunicate with people w ith what it is that they do, and they**nform** everybody what they're d oing so that we know and that way can prepare for anything that migh t be pr esented to us, any situatio n that cou ld come up.
66
As corporations go, they are probably one of the , if 2 not the, 110st coop e rative of any in the area. They do 3 that very well. They open their doors to us , and we 4 appreciate that very much. on the**econ~ic** side of that, Page 58

VES 0047970 5 6 7 8 9 10 11 12 13 14 15 1 6 17 18 19 20 21 22 23 24 25 070908a not only many of the people that I grew up with are now**enploye~s** of veolia

-- am 1 saying that correctly? Just wanted to make sure that's correct. But there 's also just a huge impact from them on the economic front from a ll of our other businesses there from buying goods and services from local vendors to the restaurants to th e peopl e that live there

-- that live there and pay property taxes and participate in our**c~n1ty.** so they are very good partners on that front as well. From the coomun 1 ty standpoint of helping with our children, the re's any number of things from h elping with community baskets in the winterti me for the senior citizens, people who are unable to afford food , various items that they contribute to, as well as to the youth activities and the community, and there's many of them

· instead of just one or two. so they help with everything from all sorts of activities. so for our comu nity, for us, veolia ha

. s been very good to work with and work for us and our community. Unlike nany other businesses, they have been very open and welcoming to anyone to come down and visit
67

1 and see their site and to keep us informed. some 2 corporations ten d not to do that. They have had an open3 doo r policy with us. T hey've had an open-door policy 4 with our**fir~** depart,.ent, our police department, our 5 administration and al l of our l ocal businesses. 6 we do not always get that opportunity to work with 7 corporations that way. so from that perspective , veol i a Page S9

VES 0047980 8 9 10 ll 12 l3 14 15 16 17 18 19 20 21 22 23 24 25 070908a has been very proactive in**suppor~ing** our community and also inf ormi n g our communiw of any dangers or any questions that we may need to get reso l ved

. They are, as I said, the most proactive in the region that I'm aware of, as far as making people informed about what it is that**~hey** do and how they do it. So I'm h e re to suppo r t them and their permitting process. 1 believe they have a safe and efficient operation that makes the region stronger for them being her e. so , w i th that , I think that's all I have to say, and I'd like to thank everybody for let t ing me have the t ime to tal k thi s evening. MS

. POPE: Next spea ker will be George Paddock

. MR

. PADDOCK: I came here initially to observe , but I think I've been called to speak. Again, George Paddock, P-A-o-o-o-c-K

. Arguing over the s ign size and where i t's posted is trivial

. If you ' re coming to inform or to be i nformed, you have some responsibilities , one of
68
1 them is to find your way to t h e me et ing. I have t aught 2 classes t o**~he** underprivileged and have taught and made 3 the privileged experience the trials and**ibu la** **~ion s**  of 4 the poor. And I have realized we all have 5 responsibilities, and some of th em are to make it to 6 i m portant hearings such as this. 7 Regarding this h earing, whether the economic impact 8 is good or bad is not t he bottom lin e here

. whether we 9 end jobs is not t h e bottom li ne . The bottom lin e is, is 10 it safe? The city and state speakers mi ssed the point, 11 some of them. Jobs are**no~** the point. Yes, it is Page 60

VES 004799